Threat-Maker’s Dad Properly Restrained From Having Guns

Wednesday, February 18, 2026

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Court of Appeal:

Threat-Maker’s Dad Properly Restrained From Having Guns

Opinion Says Judge Did Not Err in Imposing Gun Violence Restraining Order on Law-Abiding, Live-in Father Based in Part on Police Finding Key Fob to Empty Firearm Safe in Readily Accessible Spot During Search

By Kimber Cooley, associate editor

Div. Three of the Fourth District Court of Appeal has affirmed a restraining order that requires the live-in father of a man who threatened to shoot up a school to turn in, and refrain for possessing, any guns for a period of three years, finding no error in the trial judge’s conclusion that a requirement that the restrained person must be found to pose a “danger of causing…injury” may be met where a party did not adequately prevent access to firearms in the home.

Even though there was no evidence that the father—an allegedly law-abiding mechanical engineer who testified that he locked up all firearms—directly posed a danger to anyone, the court declared that the trial judge acted within his discretion in finding that the party had allowed his son, who had mental health issues, access to weapons based on the two having participated in hobby-shooting and the fact that a remote to an empty gun safe was left out in the open.

At issue is Penal Code §18175, which provides that “the petitioner has the burden of proving, by clear and convincing evidence, that” the party to be restrained “poses a significant danger of causing personal injury to themselves or another” and that “gun violence restraining order is necessary…because less restrictive alternatives either have been tried and found to be ineffective, or are inadequate or inappropriate.”

Orange Superior Court Judge Julianne S. Bancroft, sitting by assignment, authored the opinion, filed Jan. 16 and certified for publication on Friday, declaring that the law may be applied to impose a so-called “gun violence restraining order” (“GVRO”) on third parties who are not accused of any threatening or violent conduct. She wrote:

“The GVRO statute would be ineffectual if the ban could not be applied to those…who enable, however unintentionally, the threat of violence by others. Accordingly, viewing the evidence in the light most favorable to the trial court’s decision, we conclude the court properly granted the [restraining order].”

Acting Presiding Justice Eileen C. Moore and Justice Nathan Scott joined in the decision.

Threatening Text Message

The question arose after Anaheim Police Department Investigator Robert Reams received a tip that Tyler Crockett had sent a text message to an undisclosed party threatening to shoot up his alma mater, Savanna High School, on Jan. 23, 2023. Tyler Crockett had graduated from the institution approximately 10 years earlier, and, upon questioning, admitted to sending the message after becoming frustrated with a former classmate.

According to Reams, Tyler Crockett told him that, “if he were to go to the high school,…people would die.” His father, John Crockett Jr., told investigators that his son had been subjected to an involuntary psychiatric hold due to experiencing a mental health crisis on three occasions, the most recent of which was 8 years earlier.

John Crockett claimed that he was unaware that his son had been placed under a lifetime prohibition on possessing firearms as a result of his mental health history but said that Tyler Crockett did not have the code to the firearm safes used to secure his weapons.

Temporary Order

Orange Superior Court Commissioner Glenn Mondo, sitting as a temporary judge, granted Reams’ request for a temporary GVRO on Jan. 26, 2023. The father was ordered to turn in all firearms and ammunition within 24 hours.

On Jan. 27, John Crockett turned in numerous items to the police department and signed a statement swearing that he did not have or own any other prohibited materials.

After obtaining a search warrant to look for other possible weapons at the family home, Reams discovered multiple firearm parts, ammunition, high-capacity magazines, and tools used for manufacturing bullets, as well as two safes, one of which was openable by a remote control that was found lying on a nearby mantle. The key-fob-operated strongbox was empty at the time of the search, but it contained a foam cutout for storing an AR-15 style rifle.

At an October 2023 hearing, Mondo found that John Crockett posed a significant danger of causing personal injury by possessing firearms in the home that he shared with his son, noting trips to the gun range as well as the accessible remote to the empty safe, and imposed a three-year GVRO.

Many, Many Firearms

Bancroft pointed out that Mondo noted that Crockett had at one point possessed “many, many firearms” and found the restrained party’s assertion that he had not stored any firearms in the remote-operated safe during the six months leading up to the search to be not credible. Based on these and other findings, she opined:

“Tyler [Crockett] admitted having made threats…to commit a shooting at Savanna High School if he were to obtain a firearm. [John] Crockett did not adequately secure his firearms from [his son], who lived with him. The key fob to the wall-mounted gun safe was found on the mantel beneath the gun safe. [John] Crockett did not timely turn in all his firearms and ammunition. He also let Tyler handle…firearms at…competitions and gun ranges in 2022….”

The jurist added:

“That [John] Crockett himself did not directly pose a ‘significant danger’ of committing gun violence does not mean he could not be subject to a GVRO. The Anaheim Police Department showed by clear and convincing evidence [John] Crockett could not adequately prevent his son from accessing his firearms, and his son did pose a significant threat of gun violence.”

Addressing an argument that Mondo erred in interpreting the phrase “significant danger of causing personal injury” to include the father’s actions, Bancroft remarked:

“[T]he GVRO statute….is a forward-looking statute….Here, the danger arises…from [John] Crockett’s own conduct, including failure to safely secure his firearms from Tyler, failure to educate himself about the scope of Tyler’s firearms ban, and failure to fully comply with the emergency GVRO’s requirement that he turn in all firearms and ammunition. Accordingly, the trial court reasonably interpreted the word ‘causing’ to include [John] Crockett’s actions in failing to secure his guns and ammunition.”

Rejecting the view that the term “causing” is unconstitutionally vague as used in the section, she commented:

“The fact the trial court acknowledged this case did not involve the typical situation where the person subject to the firearm prohibition was likely to cause the risk of personal injury himself does not, without more, make the statute unconstitutionally vague. The court engaged in reasonable statutory interpretation in concluding the GVRO statute also applied to individuals like [John] Crockett, whose failure to adequately secure his firearms enabled his son…to cause potential harm to others.”

She also declined to find that a trial court must “specifically list, on the record, every possible alternative before concluding these alternatives would be inappropriate under the particular circumstances” and declared that John Crockett had forfeited any Second Amendment arguments by failing to raise them during the hearing on the GVRO.

The case is Anaheim Police Department v. Crockett, 2026 S.O.S. 442.