In Lilley v. Elk Grove Unified School Dist. (1998) 68 Cal.App.4th 939, plaintiff was injured during an after-school wrestling program while the instructor was demonstrating a certain control hold. The Court held the general duty of supervision under Education Code section 44807 did not foreclose the application of primary assumption of the risk to those risks inherent in school sports, emphasizing that school sports are consistent with the school's educational goals. (Id. at pp. 945-946.) The Court found that Lucas v. Fresno Unified School Dist. (1993) 14 Cal.App.4th 866 did not compel a contrary conclusion: "It is enough to note that plaintiff's participation in the extracurricular sport of wrestling clearly is within the policy purview of primary assumption of the risk, whereas a young child's participation in an unsupervised dirt clod fight clearly is not." (Id. at p. 947.)