of active shooter drills, whether this is the best approach to school safety, and the possibility of
alternatives. Part V will look at the impact the legislation has for current and future students as
well as potential results and overreached boundaries of the school districts, and any potential
II. A HISTORY OF SCHOOL SHOOTINGS
A. School Shooting History: A Look at the Most Deadly and Publicized School Shootings in the
Past Two Decades
On April 20, 1999, two students carried out what was then the worst mass school
shooting in American history.13 That morning, Eric Harris and Dylan Klebold entered Columbine
High School armed with semi-automatic weapons. Within twenty minutes, the two had killed
thirteen people, twelve students and one teacher, and wounded over twenty others.14 Later, it was
revealed that they had originally planned the incident to include a bombing, but the planted
bombs never detonated.15 The nation watched footage of the attack with horror, launching a new
age of gun control discussion and legislation, as well as new issues surrounding how to handle
violence in schools.16 After United States v. Lopez, it seemed as though government standards for
gun control were becoming more relaxed,17 but the attack on Columbine changed that. In the
twelve months after the Columbine shooting, lawmakers proposed more than eight hundred bills
having to do with guns in one form or another.18 The bills were on both ends of the spectrum,
with some protecting gun control and others promoting gun ownership rights.19 However, only
ten percent of those bills actually passed,20 and experts were sharply divided as to the
effectiveness of those bills that did.
Almost eight years later, Seung-Hui Cho carried out the deadliest school shooting
rampage the United States had ever seen at Virginia Tech University, and the problem expanded
to include the nation’s college campuses.21 Cho was a senior at Virginia Tech, and on April 16,
2007, he carried out two separate shootings on campus, one in a residence hall and the other in a
campus building where classes were being held.22 Amidst the chaos, as terrified students fled or
took cover in university buildings, Cho shot and killed thirty-two people on campus before
eventually taking his own life.23 In the aftermath of the shooting, there was yet again an urgent
call for legislation to address gun control issues.24 This time, then-President George W. Bush
signed federal legislation improving the National Instant Criminal Background Check System, as
well as a law giving states the funding to “improve their own firearms reporting systems.”25
13Greg Toppo, 10 Years Later, the Real Story Behind Columbine, USA TODAY (Apr. 14, 2009, 1:48 PM),
14 Columbine High School Shootings, BRITANNICA.COM, http://www.britannica.com/EBchecked/topic/1528263/Columbine-High-
School-shootings (last visited Apr. 15, 2015).
15 Toppo, supra note 13.
16 See id.
17 See generally, United States v. Lopez, 514 U.S. 549, 631 (1995) (holding the Gun-Free School Zones Act unconstitutional because
Congress did not have sufficient power under the Commerce Clause to enact it).
18Francie Diep, How Many Gun Bills Pass After Mass Shootings: Very Few, POPULAR SCI. (Sept. 18, 2013),
21Christine Hauser & Anahad O’Connor, Virginia Tech Shooting Leaves 33 Dead, N.Y. TIMES (Apr. 16, 2007),