SANTA ANA, Calif. — In a published opinion issued Feb. 13, 2026, the California Court of Appeal for the Fourth Appellate District, Division Three, upheld a lower court’s decision to issue a gun violence restraining order against a father after authorities found he failed to secure firearms from a son who had made threats of a school shooting and was subject to a lifetime firearm ban.
The appellate court affirmed the Superior Court of Orange County’s issuance of the gun violence restraining order, or GVRO, against the father.
The case emerged in early 2023 when Anaheim Police Department Investigator Robert Reams responded to a call concerning text messages sent by the son. The court found that in these messages the son made threats toward a local high school, including threats of using a firearm.
After conducting interviews with the father and son, Reams learned that the son had a lifetime firearm ban following multiple mental health incidents.
Soon after, Reams requested that the Superior Court of Orange County issue a GVRO against the father, which would require him to surrender his “many, many firearms and a great deal of ammunition,” according to the appellate court’s opinion.
The court granted a temporary GVRO, and the father surrendered only three of the 10 listed firearms, claiming that the rest had been sold or destroyed. The lack of official notices of sale or destruction, as well as the firearms he did return not constituting complete weapons, created suspicions that the father was still in possession of firearms.
Reams obtained a search warrant for the father’s home and found several unsurrendered firearms.
The court found that the father’s “conduct, a pattern of failing to secure weapons, allowing his troubled son access to weapons despite a lifetime prohibition, and, frankly, his allowing such acts [while] knowing of his son’s mental health history all posed a significant danger of causing injury to another by having weapons in his custody or control” and issued a three-year GVRO against the father.
The father appealed the decision to the California Court of Appeal, and the Fourth Appellate District, Division Three, reviewed the case.
The father argued in his appeal that the trial court did not consider reasonable alternatives, that the ruling was not supported by substantial evidence and that the ruling violated his Second Amendment rights.
The appellate court rejected all of these claims.
Addressing the question of substantial evidence, the court stated in its opinion, “The Anaheim Police Department showed by clear and convincing evidence [the father] could not adequately prevent his son from accessing his firearms, and his son did pose a significant threat of gun violence.”
The court also determined that because the father made no arguments on the basis of the Second Amendment to the United States Constitution in the trial court, the issue was not properly before the appellate court.
When evaluating the lower court’s consideration of alternatives, the appellate court concluded that no less restrictive means would have been effective in preventing gun violence.
In its opinion, the court stated, “[The father] had failed to adequately safeguard his firearms from [his son] and to timely turn over all his guns and ammunition to the police.”
As of Feb. 18, 2026, there had already been 55 mass shootings in the United States, according to a website that collects data on shootings nationwide. States such as California have adopted GVRO laws to curb gun violence and identify potential attackers.
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