California high school shooter ruling follows evolving approach to juvenile offenders

For many, it was a surprise when a San Diego judge issued a ruling last week that could see the region’s most notorious school shooter freed from prison at age 39.

But a series of laws and court rulings favoring rehabilitation for youth offenders for more than a decade have paved the way for the possible release of Santana High School shooter Charles “Andy” Williams, who killed two classmates and wounded 11 more students and two adults in March 2001.

RELATED: Victims react with disappointment, frustration at possible release of California school shooter

No longer can anyone under age 16 be charged as an adult in California courts. Parole is now available to youth offenders after serving 25 years of their sentence. And lawmakers have created a path for youths previously sentenced to life without the possibility parole to seek relief.

Then there are those like Williams, who, at 15 years old, was sentenced to 50 years to life in prison. Recently, courts have been grappling with the question: When does such a lengthy sentence become a de facto sentence of life without parole?

Last week, San Diego Superior Court Judge Lisa Rodriguez found that such a lengthy sentence is essentially life without parole. She recalled — or essentially, erased — Williams’ sentence and set him to be resentenced in Juvenile Court. There, he will get the benefits of today’s laws governing juvenile offenders, and that likely translates into a release from custody. The District Attorney’s Office is appealing.

On Tuesday, as survivors of the Santana High rampage listened in, the judge explained her decision, saying she was following the guidance set by the San Diego-based 4th District Court of Appeal, Division 1, which she said “has made its position on this issue clear.”

It is the same appellate court — although not necessarily the same panel of judges — that will review the district attorney’s appeal of the Williams decision.

Victims of and witnesses to the rampage expressed disappointment and concern following the ruling, with at least one questioning whether the decision was moral or just. Many pointed to the deaths of students Bryan Zuckor, 14, and Randy Gordon, 17.

In a statement issued last week, District Attorney Summer Stephan said Williams had “carried out a calculated, cold-blooded attack” and that his “cruel actions in this case continue to warrant the 50-years-to-life sentence that was imposed.”

“At some point our laws must balance the rights of defendants, the rights of victims, and the rights of the community to be safe,” Stephan said.

Had the Santana attack happened today, a 15-year-old shooter — even if convicted of multiple murders — would be tried as a juvenile and generally could not be held in custody longer than age 25, with maybe an additional two years in transitional housing.

State Assemblymember Carl DeMaio, whose district includes Santee, said last week he is developing legislation that would exclude those who commit school shootings and similar mass-casualty crimes from resentencing laws offering relief to juvenile offenders.

“School shootings are not impulsive mistakes — they are acts of terror,” DeMaio said in a statement. “California’s laws should draw a bright line: if you commit mass violence in a school, you should never be eligible for resentencing designed for lesser offenses.”

People who work with juvenile offenders note that the courts and lawmakers have come to understand that teens are different from adults and should be given the chance at rehabilitation and release. They point to scientific research on the lack of adolescent brain development and the ability for juvenile offenders to be rehabilitated.

“I think that the question we ought to be answering is, ‘Do we want to throw away people who do something terrible at age 15?’” said law professor Christopher Hawthorne, director of the Juvenile Innocence and Fair Sentencing Clinic at Loyola Marymount University, which takes on post-conviction cases for juvenile defenders.

Hawthorne said lawmakers “woke up” in 2012 and began giving juvenile offenders a path for release.

San Diego defense attorney Danni Iredale, who represents clients in federal and state court, including juveniles, said that while she understands some may believe that juvenile offenders should be given harsher sentences — especially in “outlier” cases such as the Santana shooting — she believes strongly in the research on brain development and rehabilitation.

“There’s always going to be an outlier case that pushes us to the bounds of what we can tolerate, but … juveniles are different, and I think the Supreme Court has recognized that time and time and time again,” she said.

An evolving approach

Juvenile sentencing laws have evolved since Williams was initially sentenced in 2002. While not all of the changes directly impacted Williams, they had a cascading effect that ultimately led to this past week’s ruling.

The first big decision came in 2005 when the U.S. Supreme Court banned the death penalty for juvenile offenders, ruling that it violated the Eighth Amendment restriction against cruel and unusual punishment. The Supreme Court also issued rulings in 2010 and 2012 that limited the ability of states to sentence juveniles to life in prison without parole.

Those laws laid out a more nuanced viewpoint of the distinctions between adults and juveniles who commit the worst crimes and the unconstitutionality of punishing them equally.

As a California appeals court wrote in 2022: “These decisions arose in large part from advances in research on adolescent brain development, and the related, growing recognition that juveniles ‘have diminished culpability and greater prospects for reform’ and are therefore ‘constitutionally different from adults for purposes of sentencing.’”

The Supreme Court rulings prompted legislative changes in some states, including California. Those changes, plus subsequent court rulings, did eventually have a direct impact on Williams.

California Senate Bill 9, which took effect in 2013, allowed juvenile offenders serving life without parole to petition to have their sentences recalled and to be resentenced. Since Williams was not sentenced to life without parole, the law did not initially affect him. But that changed in 2022 in a decision arising from another case involving a juvenile offender from San Diego.

In 2005, when Frank Heard was 15 years old, he and other members of his San Diego street gang wounded two people in a drive-by shooting targeting rival gang members. Six months later, shortly after Heard turned 16, he fatally shot a person on a street corner who he believed was selling drugs in his gang’s territory.

Heard was charged as an adult and convicted of attempted murder and manslaughter charges. A judge sentenced him to what essentially amounted to 103 years to life in prison.

Heard filed an appeal in 2021, citing the 2013 law, arguing that he should be eligible for resentencing “because his sentence was a de facto life without parole sentence.” A San Diego Superior Court judge denied the appeal, ruling the law only applied to juvenile offenders explicitly sentenced to life without parole. Heard appealed that ruling, arguing that his sentence was the “functional equivalent” of life without parole.

In 2022, California’s Fourth Appellate District agreed with the San Diego judge that the 2013 statute only applied to juvenile offenders explicitly sentenced to life without parole. But Heard had also argued that if the law did not apply to him and others with sentences functionally equivalent to life without parole, it would violate his rights to equal protection of the laws under the 14th Amendment and the California Constitution.

“On this, we agree,” the appellate court wrote.

The ruling allowed similarly situated juvenile offenders such as Williams to petition for a resentencing — if, like Heard, they could successfully argue that their lengthy prison terms were the functional equivalent of life without parole.

A flood of petitions for resentencing followed. Williams’ attorney said last week that her client initially declined to petition because he wanted to have a parole hearing first, in order to give his victims a chance to confront him. And even that parole hearing was possible under reforms that now offer parole hearings for youth offenders who have served 25 years of their sentence.

At that parole hearing in September 2024, Williams was found unsuitable for release. One commissioner told Williams it was “unclear if you understand why you committed this horrendous act of violence.”

Williams then filed a petition to have his sentence recalled. But then, in the last year, differing appeals courts in California handed down opinions contrary to the Heard finding.

What exactly constitutes the functional equivalent of life without parole is still up for debate. With now competing decisions in trial and appellate courts, the California Supreme Court agreed last year to take up the question, but that action is still in its infancy. It is not clear if the prosecutors in Stephan’s office will ask the Juvenile Court to pause Williams’ case until the high court rules.

As for case law, Rodriguez, the judge in Williams’ matter, said one case that stood out was a 2018 California Supreme Court ruling that 50 to life was equal to life without parole. That ruling arose from a San Diego case in which two 16-year-olds came across two teen girls in a Rancho Peñasquitos park in 2011, kidnapped and raped them. In that case, the state’s high court said it agreed with the San Diego appellate court finding that the lengthy sentences tended to reflect a judgment that the two defendants were “irretrievably incorrigible” and fell short of a realistic chance for release. 

Fewer teens can be tried as adults

The venue for Williams’ resentencing is also the result of state laws that have changed in recent years.

In 2016, California voters approved Proposition 57, a measure that required prosecutors to seek a hearing if they wished to charge 14- and 15-year-old offenders as adults. A few years later, in 2018, state legislators passed a law that banned offenders 15 years old and younger from being charged as adults in any circumstances.

There was another big change geared toward placement of youth offenders in 2021, when the Legislature agreed to do away with the Department of Juvenile Justice, which ran prisons for juvenile offenders. Since mid-2023, housing those youth offenders now falls to the individual counties, which keeps them closer to their families. In San Diego, that meant creating a wing in the East Mesa Juvenile Facility to house that population.

Williams, 39, would not be sent to such a facility, which doesn’t house people older than age 25. His attorney has said he hopes to move to Northern California.