The Anaheim Police Department (APD) sought the Gun Violence Restraining Order under Penal Code section 18175 (GVRO) after John Adams Crockett Jr.’s adult son, Tyler Crockett, who lived with him, made credible threats of a mass shooting at Savanna High School in Anaheim. Tyler had a documented history of multiple mental health holds and was subject to a lifetime prohibition on possessing firearms. After sending text messages threatening to “shoot up” the school and referencing his access to large quantities of ammunition, the APD obtained a GVRO against John Adams Crockett, who owned numerous firearms and thousands of rounds of ammunition.
At the evidentiary hearing, the trial court found the requisite clear and convincing evidence that John Adams Crockett failed to adequately secure his firearms from his son, Tyler, and that Tyler posed a significant danger of carrying out gun violence. The court determined that John Adams Crockett’s conduct to allow Tyler access to firearms, despite Tyler’s lifetime prohibition and mental health history, created a substantial risk of personal injury to others. The trial court issued a three-year GVRO, and Crockett appealed.
In the California Court of Appeal, John Adams Crockett argued there was insufficient evidence to support the GVRO, and he challenged Penal Code section 18175 on several grounds, including vagueness, overbreadth, and violation of his Second Amendment rights. The Court rejected these arguments and affirmed the order.
The Court emphasized that section 18175 is preventative and forward-looking, and that a person may “cause” a danger of injury under this law by giving another person, who poses a credible threat, access to firearms. The Court further held that the law was sufficiently clear and that Crockett forfeited several claims by failing to raise them in the trial court.
Note:
LCW attorneys regularly win Workplace Violence Restraining Orders on behalf of employers who need to protect employees. The law governing Workplace Violence Restraining Orders is Code of Civil Procedure section 527.8. Similar to Penal Code section 18175, an employer must show a credible threat of violence by clear and convincing evidence to receive the Workplace Violence Restraining Order.
Anaheim Police Dept. v. Crockett (2026) CalApp.LEXIS 101.