How have courts treated the doctrine of negligence per se?

^6. Although stated as a separate cause of action in Batton's complaint, we construe his negligence per se theory as part of his negligence cause of action. (See Millard v. Biosources, Inc. (2007) 156 Cal.App.4th 1338, 1353, fn. 2 ["[T]he doctrine of negligence per se is not a separate cause of action, but creates an evidentiary presumption that affects the standard of care in a cause of action for negligence. [Citation.]"]; accord, Johnson v. Honeywell Internat. Inc. (2009) 179 Cal.App.4th 549, 555.) As to both negligence "causes of action," Alten sought summary adjudication on the basis of the delegation-of-duty rationale we discuss above. Triable issues of material fact preclude summary adjudication on that issue.