In Guerrero v. South Bay Union School District (2003) 114 Cal.App.4th 264, the six-year-old plaintiff was struck by a car while crossing the street in front of her school, approximately 30 minutes after her release from school while she was waiting to be picked up. (Guerrero, 114 Cal.App.4th at pp. 266-267.) One of the plaintiff's opposing summary judgment arguments was "that the accident was caused by the school district's failure to properly supervise her while on school grounds." (Id. at p. 269.) In rejecting that argument, the Guerrero majority explained that under Education Code section 44808, "the school district would not be liable for injuries off campus and after school unless they were the result of the District's negligence occurring on school grounds or were the result of some specific undertaking by the District, which was then performed in a negligent manner." (Guerrero, at p. 269.) It addressed cases in which a duty had been found relative to an off-campus injury, concluding that "each of the cases in which schools have been held to have a duty of care for the safety of students off campus and after school arises from circumstances where school personnel did something on campus or failed in their supervisory duties on campus. . . . Plaintiff's case does not present any basis for constructing a duty to exercise reasonable care for her safety after she was released from school. Although she argues the District failed in its duty to supervise her while on school grounds, she does not articulate what the school's duty should have been or what action the school should have taken. No evidence was presented in the summary judgment proceeding that the District or the school supervised the public street where the plaintiff and her siblings waited to be picked up. Nor are there any facts presented to show how the on-campus conduct of the school related to the off-campus injury." (Id. at p. 270.) It found "no factual connection to the plaintiff's release from school in the company of her siblings and her unfortunate accident after she was released from school." (Ibid.) Accordingly, in Guerrero, the majority held the district in that case owed no duty of care to the plaintiff under the circumstances.