Does a secondary school have an affirmative duty to protect a student from assault by a third party?

For example, in Crow v. State of California (1990) 222 Cal.App.3d 192 (Crow), a student filed a negligence claim against a state university after being assaulted by another student inside a school dormitory. The plaintiff's complaint alleged that the school "knew of the vicious and dangerous propensities of [the attacker]," who had previously assaulted a residence hall advisor. (Id. at p. 197.) The complaint further alleged that, despite such knowledge, the university had "refused and neglected to take any action to prevent [the assailant] from continuing in his vicious and dangerous propensities and to prevent the attack, assault and battery on plaintiff." (Ibid.) The defendants moved for summary judgment, arguing that they had "no duty to control the acts of adult students." (Id. at p. 198.) The plaintiff, however, "contended . . . that his affiliation with the university as a student created . . . a special relationship" giving rise to "an affirmative duty to protect him" from the foreseeable "criminal acts of a third party." (Id. at p. 209.) In support, plaintiff cited prior case law holding that secondary schools "ha[ve] a duty to protect student[s]" from foreseeable attacks by third parties. (Ibid.)