In spite of these measures, school shootings continued to occur with alarming frequency.
On December 14, 2012, twenty-year-old Adam Lanza shot and murdered his mother in their
home, then travelled a few miles to the nearby Sandy Hook Elementary.26 After forcing his way
into the building, Lanza opened fire, killing twenty students between the ages of six and seven,
along with six adults.27 Sandy Hook Elementary made attempts at securing the building and had
recently installed a new security system, but Lanza entered the building by shooting through a
locked door, and once inside, continued his rampage.28 After the first terrified 911 call, police
radios began to broadcast the incident, and within three minutes, first responders arrived at the
school.29 Despite the rapid response time, the police report indicated that no law enforcement
officers discharged their weapons at any point.30 Lanza had finished shooting and taken his own
life before police officers reached him.31
On December 13, 2013, eighteen-year-old Karl Pierson entered an unlocked side door of
his school carrying a shotgun, a machete, three Molotov cocktails and 125 rounds of
ammunition.32 The resulting attack took less than one minute and twenty seconds.33 One student
was shot, who died later in the hospital from her injuries, before Pierson took his own life.34
Chillingly, the shooting took place in Arapahoe, Colorado, approximately ten miles from where
the Columbine shooting occurred over a decade before.35 Although much less deadly than its
predecessors, this incident helped draw even more attention to the already-escalated tensions and
divisive opinions of the national community following Sandy Hook.36 As the stories became more
frequent and the news coverage more alarming, schools began grappling to address the issue
through various means, including the proposed implementation of active shooter drills.
B. The Evolution of School Emergency Drills
School emergency drills have traditionally been conducted to prepare students and
faculty members for fires and extreme weather within those areas where they are geographically
appropriate.37 During the Cold War era, air-raid drills were prevalent, despite the now-debated
efficacy of such a practice.38
26 Associated Press, Newtown School Shooting: Facts From Sandy Hook Elementary School Massacre, HUFFINGTON POST (Feb. 15,
2013, 5:12 AM), http://www.huffingtonpost.com/2012/12/16/newtown-school-shooting-facts_n_2313116.html; Sandy Hook
Elementary School Shooting Reports, CONN. DEP’T EMERGENCY SERVS. & PUB. PROT., http://cspsandyhookreport.ct.gov/ (last visited
Apr. 29, 2015) (providing various materials from the investigation done after the Sandy Hook Shooting).
27 Sandy Hook Shooting: What Happened?, CNN, http://www.cnn.com/interactive/2012/12/us/sandy-hook-timeline/ (last visited Apr.
32 Catherine E. Shoichet, Sheriff: Colorado School Gunman Got in Through Unlocked Door, CNN (Dec. 30, 2013, 2:45 PM),
34 Tom Watkins & Ana Cabrera, Colorado’s School Shooting—Over in 80 Seconds, CNN (Dec. 15, 2013, 2:33 PM),
35 Tom Watkins & Ralph Ellis, Colorado High School Shooting Victim Dies at Hospital, CNN (Dec. 22, 2013, 11:10 AM),
36 See Republican Lawmaker Whose Son Survived Arapahoe High School Shooting Wants Armed Teachers, HUFFINGTON POST (Jan.
6, 2014, 5:36 PM), http://www.huffingtonpost.com/2014/01/06/ted-harvey-arapahoe-high-school-shooting_n_4550616.html
(describing how one concerned parent who is also a lawmaker called for arming teachers after the Arapahoe incident as a proposed
measure to protect and secure the safety of students); see also Eric Gorski, Arapahoe High School Shooting Aftermath Puts Parenting
Under Scrutiny, DENVER POST (Oct. 13, 2014, 10:58 AM), http://www.denverpost.com/news/ci_26711403/arapahoe-high-school-
shooting-aftermath-puts-parenting-under (describing the highly contentious issue of recognizing the warning signs and finding help
for mentally ill children and the blame parents may face when they do not prevent their children’s violent acts).
37 See Earthquake Safety at School, FED. EMERGENCY MGMT. AGENCY, https://www.fema.gov/earthquake/earthquake-safety-school
(last updated July 24, 2014); see Fire Drills at School, NAT’L FIRE PROT. ASS’N, http://www.nfpa.org/safety-information/for-public-
educators/education-programs/learn-not-to-burn/learn-not-to-burn-grade-1/fire-drills-at-school (last visited Apr. 15, 2015); see Roger