Rayan Zarrabi graduated from Scripps Ranch High School, part of the San Diego Unified School District, in 2019. In the years that followed, he engaged in an escalating pattern of hostility directed at two school employees – M.L., a vice principal, and D.L., one of his former teachers. A few months after graduating, Zarrabi attended an SRHS football game where he shouted profanity and raised his middle finger at D.L. In December 2022, he entered the campus without permission, was told to leave, and was then caught sneaking back in through a rear gate, after which M.L. instructed him never to return.

In May 2023, Zarrabi attended an off-campus SRHS volleyball game at Southwestern Community College, where he sent disturbing electronic messages to students that included references to graves and tombstone emojis. When M.L. told him to leave, campus police had to escort him out while he shouted vulgar insults at M.L. In June 2023, he yelled profanity at M.L. from his car as M.L. sat on a restaurant patio. Around the same time, he tracked down D.L.’s family members on Facebook and sent them hateful, profanity-laden messages attacking D.L.’s appearance and character.

In February 2024, Zarrabi contacted a coworker of M.L. and D.L. on Facebook, repeating the same type of messages and adding lengthy, hostile commentary about both men. Then, in May 2024, a witness flagged down police to report that Zarrabi had been speaking rapidly and intensely about his hatred for M.L. and D.L., stating that he hoped they would die, that they did not deserve to live, that it was all he could think about, and that he was going to get his revenge. Police prepared a crime report, a suspicious activity report, and a psychiatric emergency response team referral, and an officer advised M.L. to seek a restraining order. Zarrabi reportedly continued telling third parties, including current students, that he intended to “go after” the two employees.

In October 2024, the District filed a petition for a workplace violence restraining order under Code of Civil Procedure section 527.8 on behalf of M.L. and D.L., also requesting that M.L.’s immediate family members be included as protected persons. The trial court granted a temporary restraining order based on a credible threat of violence or stalking and set a hearing. Zarrabi filed a written response denying the allegations. Following a hearing in November 2024, the trial court granted the petition, ordering Zarrabi to stay at least 100 yards from the employees’ workplaces, homes, and vehicles, as well as from SRHS events held off campus.

The Court of Appeal affirmed the restraining order in its entirety in the unpublished case of San Diego Unified School District v. Zarrabi, No. D085415 (February 2026). The court addressed Zarrabi’s arguments on four grounds.

First, on sufficiency of the evidence, the court held that Zarrabi had forfeited this argument by failing to include a reporter’s transcript or an agreed or settled statement from the hearing.The court went on to find that even setting aside the forfeiture, the record – including declarations from M.L. and D.L., copies of Zarrabi’s electronic messages, and a police report – contained substantial evidence supporting the order.

Second, regarding the First Amendment, the court found that Zarrabi failed to present a cogent argument supported by relevant authority. It noted that the cases he cited were inapposite. Relying on City of San Jose v. Garbett (2010) 190 Cal.App.4th 526, 537, the court explained that speech constituting a credible threat of violence under section 527.8 is not constitutionally protected and may properly be enjoined.

Third, on due process, Zarrabi complained that a police officer’s declaration was filed shortly before the hearing and that he did not receive it in time. The court found he provided no evidence to support this claim, no evidence the trial court even considered the declaration, and no showing that the outcome would have been different without it, since the declarations of M.L. and D.L. alone were sufficient. The court cited City of Los Angeles v. Herman (2020) 54 Cal.App.5th 97, 105, where a similar due process argument was rejected because the defendant had the opportunity to question witnesses and present his own evidence.

Fourth, the court rejected Zarrabi’s claim that the restraining order caused him disproportionate reputational and employment harm. It found he supported this argument with neither citations to the record nor relevant legal authority.Even considering the argument on its merits, the court found that the record did not establish any harm to Zarrabi that was disproportionate to the need for protection.