On November 28, 2023, the Legislative Council of Victoria passed a bill that named one prisoner and kept him in prison. The prisoner was Paul Charles Denyer. The law was called Nat’s Law, after Natalie Russell, a 17-year-old schoolgirl from Frankston whom he had killed thirty years earlier, and in the gallery that day sat the families of all three women he had pleaded guilty to murdering.
Most laws are anonymous. They carry a number, a year and a title written by drafting clerks. A few carry a first name, usually a young one, and those names are chosen deliberately: they turn a statute into a memorial and a debate into a moral test. Lawmakers who might question a "Corrections Amendment" find it harder to vote against a girl. Some of the statutes that followed serial cases carry a victim’s name. Others carry no name at all, yet everyone who voted for them knew which case had put them on the agenda. Taken together they show what legislatures do when a court’s judgment, a parole board’s decision or a police failure leaves the public convinced that the system itself let someone down.
Denyer was 21 in the winter of 1993, when Elizabeth Stevens, 18, Debbie Fream, 22, and Natalie Russell, 17, were killed over seven weeks in the suburbs south-east of Melbourne. He pleaded guilty to three counts of murder and to kidnapping a fourth woman, who survived. On December 20, 1993, Justice Frank Vincent of the Supreme Court of Victoria gave him life on each murder count and refused to set a minimum term. He told Denyer that "for many, you are the fear that quickens their steps as they walk alone," and said he would not "abrogate my responsibility to some distant Parole Board."
In July 1994 the Court of Appeal, by two votes to one, held that it had been an error not to fix a minimum and set one of 30 years. That term ran out in 2023. The Adult Parole Board of Victoria refused his application, and the families were told on May 10, 2023. Natalie’s father told Network 10, in remarks carried by Australian Associated Press, that it was the best news he had heard in 30 years. The refusal settled nothing for good. Denyer could apply again, and the families faced the prospect of a fresh hearing every few years.
The opposition moved first. On May 17, 2023, Matthew Bach introduced a bill that would have added a section 74AC to the Corrections Act 1986, letting the board release Denyer only if he was in imminent danger of dying or was so incapacitated that he could harm no one. It copied provisions Parliament had made earlier for two other prisoners, Julian Knight and Craig Minogue, which the High Court had upheld in 2017 and 2019. The Labor government opposed it. The Attorney-General, Jaclyn Symes, said a wider reform was better than "one-man legislation." On June 21 the Legislative Council voted the bill down, 19 votes to 17, with Natalie’s sister, her best friend and Debbie Fream’s son watching from the gallery. The families told AAP it was one of the worst days they had lived through since Denyer applied for parole.
On October 31, 2023, the government reversed itself, after meeting the families and receiving advice from the Solicitor-General that a High Court challenge from Denyer was unlikely to succeed. Its own Corrections Amendment (Parole Reform) Bill was introduced the next day. In its Charter statement the government accepted that the section naming Denyer might be incompatible with his human rights and said the community should have confidence that he would not be released "until he can do no harm." The Legislative Assembly debated it on November 16, and in the course of that debate corrected the bill’s description of his life terms from "consecutive" to "concurrent," which is what the Supreme Court’s order had made them. The Council passed it without amendment on November 28. It became Act No. 36 of 2023.
The new section 74AC lets Denyer out only if he is in imminent danger of dying or seriously incapacitated, can no longer harm anyone and is no longer a risk to the community. Paul Edbrooke, the member for Frankston, called it Nat’s Law and said it would ensure that "people who belong in prison, stay in prison." The same act reached well past one man. It created a class of "restricted prisoners," serving life for two or more murders, for the murder of a child, or for a murder that came with a sexual offense against the same victim, whom the board can bar from applying for parole for five to ten years after their minimum terms end. AAP reported that the changes would affect 32 people in custody. The Victorian Bar and the Criminal Bar Association opposed the reforms, arguing that the 1994 ruling had always left the board free to say no.
Levi Bellfield did not inspire a law with a victim’s name on it. He inspired one that took effect early because of him.
A jury at the Old Bailey convicted him in February 2008 of murdering Marsha McDonnell, 19, and Amelie Delagrange, 22, and of the attempted murder of Kate Sheedy, 18, who survived. Mrs Justice Rafferty imposed a whole life order. In June 2011 a second jury convicted him of the kidnapping and murder of Milly Dowler, 13, in Walton-on-Thames in March 2002, and Mr Justice Wilkie imposed another whole life order, reported at the time as the first time anyone had received two.
By May 2022 Bellfield was held at HMP Frankland in County Durham, and the Ministry of Justice confirmed that he had applied to marry a woman who had been visiting him. The prisons minister, Victoria Atkins, ordered an immediate review and called the plan "absolutely appalling." The law gave her little to work with. Prisoners serving whole life orders could apply to marry, and a governor could refuse only on security grounds. In March 2023 the government announced that it would bar whole life prisoners from marrying or forming civil partnerships, and in June 2023 the Ministry of Justice conceded that "under current laws there are no legal routes to block this marriage."
The restriction arrived through the Victims and Prisoners Act and came into force on August 2, 2024. By then Bellfield had withdrawn his marriage application and applied for a civil partnership instead; that application was blocked the day the provision took effect, and his case was believed to have prompted the government to bring the restriction in early. The Lord Chancellor keeps a power to allow a ceremony in the most exceptional circumstances. "Victims should not be tormented by seeing those who commit the most depraved crimes enjoy the moments" in life, the Justice Secretary, Shabana Mahmood, said. The law names no one. Everyone who reported on it named Bellfield.
Some named laws travel. They are written for one case and then govern thousands of others, until the name becomes a piece of procedure that families invoke without knowing who it honors.
Marsy Nicholas was a student at the University of California, Santa Barbara, who was killed by a former boyfriend in 1983, at a time when, in the words of the California Attorney General’s office, basic victims' rights did not exist. On November 4, 2008, California voters approved Proposition 9, known as Marsy’s Law. It wrote into the state constitution a list of rights for crime victims, among them the right "to be treated with fairness and respect for their privacy and dignity" and the right to be heard, upon request, at any proceeding involving a plea, sentencing or post-conviction release decision.
On February 3, 2017, in Orange County Superior Court in Santa Ana, that right was exercised by four mothers. Steven Dean Gordon had been convicted on December 15, 2016, of four counts of first-degree murder with special circumstances of kidnapping and multiple murder, for the deaths of Kianna Jackson, 20, Josephine Monique Vargas, 34, Martha Anaya, 28, and Jarrae Nykkole Estepp, 21, between October 2013 and March 2014. He had acted as his own lawyer. Under Marsy’s Law, family members of each woman addressed the court before he was sentenced to death. "I’m so glad that you cannot do this to another woman ever again," Jarrae Estepp’s mother told him. Kianna Jackson’s mother and grandmother both said death was the right sentence.
The Gordon case also exposed the limits of a different kind of law. Gordon and his co-defendant, Franc Cano, were both registered sex offenders wearing GPS ankle monitors, Cano under state parole and Gordon under federal probation, and both had been told to keep apart. The California Department of Corrections and Rehabilitation said that GPS shows where an offender has been but cannot detect a crime in progress, and that its monitors were not designed to alert staff when one offender met another. On April 16, 2014, a spokesman for Darrell Steinberg, president pro tem of the California Senate, said Steinberg wanted the corrections inspector general to review how parole agents had monitored Cano and perhaps whether GPS prevents crime at all. Cano pleaded guilty on December 15, 2022, and was sentenced to life without parole. As of that month the district attorney described Gordon’s automatic appeal as ongoing.
In the summer of 2005 the Pacific Northwest learned the name of Joseph Edward Duncan III, and the legislatures of two states went to work.
Duncan pleaded guilty in Idaho state court in October 2006 to three counts of first-degree murder, with other charges, for the deaths of Brenda Groene, 40, Mark McKenzie, 37, and Slade Groene, 13, in Kootenai County in May 2005. In federal court he pleaded guilty to charges covering the death of Dylan Groene, 9, and a federal jury returned three death sentences in August 2008. Dylan’s eight-year-old sister survived. In 2011 Duncan pleaded guilty in Riverside County, California, to the murder of Anthony Martinez, 10, in 1997. When the Idaho killings came to light he was free on 15,000 dollars bail on a pending charge in Becker County, Minnesota. "In retrospect, there’s no way to defend it," the county attorney, Joe Evans, said of the bail decision in July 2005.
Washington moved first. In the summer of 2005 lawmakers proposed mandatory life sentences for the gravest sex offenses and electronic monitoring of released offenders, and in 2006 the state set 25-year mandatory minimum terms for many sex offenses, allowed electronic monitoring and created a new crime of criminal trespass against children. Idaho followed the same year with a "two strikes" law imposing life on designated violent sexual predators who offend again, a ban on sex offenders coming within 500 feet of schools when children are present, and tighter registration rules. One Idaho measure, inspired by the case, raised the cap on crime victim counseling payments from 2,500 to 25,000 dollars in certain circumstances. It was a small figure on a large page of legislation, and it was the only one written with the survivors in mind rather than the next offender.
None of those statutes bears a child’s name. Duncan died of brain cancer on March 28, 2021, at a hospital near the federal prison at Terre Haute, Indiana, with no execution date set.
Canada has a habit of answering a scandal with an inquiry and the inquiry with regulation. The case of Paul Kenneth Bernardo produced both.
A jury in Toronto convicted Bernardo on September 1, 1995, of the first-degree murder of Leslie Mahaffy, 14, and of Kristen French, 15, with other charges. He was declared a dangerous offender that November, and the Supreme Court of Canada refused him leave to appeal on September 21, 2000. Long before then, it had become clear that police forces in Toronto and the Niagara region had held pieces of the same puzzle without putting them together.
Justice Archie Campbell’s Bernardo Investigation Review, released in 1996, held no hearings and had no power to compel evidence. Its central recommendation was a common case management system, backed by regulation, for investigating homicides and sexual assaults across police forces. Ontario announced in 1997 that it would carry out the recommendations and set aside 25 million dollars over five years. A centre for linking violent crimes through ViCLAS, the Violent Crime Linkage Analysis System, opened in December 1996, and reporting to it was made mandatory under the Police Services Act in February 1997. The Ontario Major Case Management System followed in 2000, and since January 1, 2005, a regulation under the same act has required every police service in the province to use it. In 2012 British Columbia’s Missing Women Commission of Inquiry quoted Campbell’s findings on systemic failure as still relevant.
The regulation carries no name. Bernardo was still in custody as of September 21, 2026, held at La Macaza Institution, with a parole hearing postponed to January 2027.
In Chile the law that changed came before the killing it was later said to have been able to prevent.
Hugo Bustamante was convicted in 2005 of killing his former partner, Veronica Vasquez, 49, and her nine-year-old son, Eugenio, in Villa Alemana, and was sentenced to 27 years. In April 2016 the parole commission of the Valparaiso Court of Appeals, chaired by Judge Silvana Donoso Ocampo, released him after about 11 years. He was one of 787 prisoners freed under the same decision, Meganoticias reported. The commission relied on Decree Law 321, whose second article let a prisoner sentenced to more than 20 years apply for parole after serving ten. The prison service, Gendarmeria, had advised against it, describing him as an inmate who "requires intervention and a longer period of observation inside prison." Judge Donoso said Gendarmeria’s reports were not binding.
The mass releases of 2016 drew a bill from Senators Pedro Araya, Alberto Espina, Felipe Harboe and Hernan Larrain. The reform was promulgated in January 2019, Emol reported. It required prisoners convicted of parricide, femicide, aggravated homicide, robbery with homicide, infanticide and certain other grave crimes to serve two-thirds of their sentences before applying, and required a psychosocial report from Gendarmeria on the risk of reoffending, including the applicant’s awareness of the gravity of the crime.
It came too late to matter in Bustamante’s case. In July 2020 Ambar Cornejo, 16, the daughter of his new partner, was killed in Villa Alemana, and on August 6 Bustamante and the girl’s mother were detained. President Sebastian Pinera wrote that his government had "already toughened the parole law that would have prevented this murder." In September 2020 the Chamber of Deputies approved a constitutional accusation against Judge Donoso, and on September 24 the Senate rejected it. On December 7, 2021, a court in Vina del Mar sentenced Bustamante to presidio perpetuo calificado, the most severe penalty in Chilean law, for the murder of Ambar Cornejo, with other charges. Her mother was convicted with him. The Supreme Court upheld both sentences in June 2022, and as of October 26, 2026, Bustamante was serving that sentence.
Julio Perez Silva was arrested on October 4, 2001, in the far north of Chile. A judge in Iquique convicted him in February 2004 of fourteen aggravated homicides and one attempted homicide, with other charges; most of the victims were teenage girls from Alto Hospicio, a settlement above the port of Iquique. In September 2005 the Iquique Court of Appeals raised the main sentence to qualified life imprisonment, which requires at least forty years before any prison benefit can be sought, and the Supreme Court ratified it in October 2006, Cooperativa reported.
For close to three years before his arrest, police and officials had told the families that the girls had probably run away. When the Ministry of Cultures, Arts and Heritage declared the Iquique mausoleum where most of the victims lie a historic monument, by a decree published on March 24, 2026, the National Monuments Council cited, among its reasons, the fact that the case came before Chilean law explicitly recognized femicide. The decree lists fourteen names, from Graciela Monsterrat Saravia Tapia to Angelica Miryam Palape Castro.
Law reached back into the case from the other direction in 2026. In January the Justice Minister, Jaime Gajardo, warned that a Senate bill allowing older or seriously ill prisoners to serve their sentences outside prison could benefit Perez Silva, T13 and El Dinamo reported. The Senate approved the bill in general in March 2026, according to El Dinamo, which listed him among the prisoners who might apply. Whether he would qualify under the final text had not been settled. In March 2026 he was serving qualified life imprisonment at Colina 1, aged 62.
The last of these cases produced no law named after anyone. It produced a method, and then rules to contain it.
Joseph James DeAngelo pleaded guilty on June 29, 2020, in Sacramento County Superior Court to 13 counts of first-degree murder and 13 counts of kidnapping to commit robbery, for crimes committed in California between 1975 and 1986. He admitted many other crimes that the statute of limitations had put beyond the reach of a charge. On August 21, 2020, Judge Michael Bowman sentenced him to 11 consecutive terms of life without parole and further terms. He had been identified in 2018 through investigative genetic genealogy, by comparing DNA from the crimes with profiles that private citizens had uploaded to genealogy websites to find relatives.
Those citizens had not agreed to help the police. The United States Department of Justice issued an interim policy on forensic genetic genealogy, effective November 1, 2019, that limits its use by federal agencies to violent crimes, chiefly homicides and sexual offenses, and to identifying suspected homicide victims. Under the policy a genetic association is a lead only, and no arrest may rest on it alone. In 2021 Maryland and Montana passed laws restricting police use of consumer DNA databases. Maryland’s requires a judge’s approval and limits the method to serious crimes. Montana’s requires a warrant unless users have waived their privacy rights.
Set side by side, the cases split cleanly. Where a victim’s name went on a law, a family had kept it in front of the public for years: the Russells and the other Frankston families campaigned from 2021, sat through a defeat in June 2023 and were in the gallery for the vote in November. Marsy Nicholas’s name became a constitutional right that four Orange County mothers used without needing to explain it. Where no name went on the law, the change usually aimed at a system rather than a person: a parole rule in Chile, a police regulation in Ontario, sentencing minimums in Washington and Idaho, a privacy policy in Washington, D.C.
The named laws are also the narrowest. Nat’s Law’s best-known provision governs a single prisoner, which is why the Victorian government at first called it "one-man legislation" and why the Bar opposed the reforms built around it. The anonymous laws reach much further, and their authors rarely claim that they would have stopped the crime that inspired them. Pinera did, about a reform that predated Ambar Cornejo’s death, and Bustamante had been released under the old rule nearly three years before the new one took effect.
What the statutes cannot do is reach back. Denyer was sentenced in 1993 by a judge who wanted no minimum term; it took thirty years and an act of Parliament to restore what Justice Vincent had ordered. Bellfield’s marriage ban came after his application had already been made. The Idaho counseling cap was raised for survivors of crimes already committed. Each of these laws was written for the next case, and each was paid for by the one before it.
• December 20, 1993: Paul Denyer is sentenced to life on three counts of murder, with no minimum term.
• July 1994: Victoria’s Court of Appeal sets a 30-year non-parole period for Denyer.
• September 1, 1995: Paul Bernardo is convicted of the first-degree murder of Leslie Mahaffy and Kristen French, with other charges.
• 1996: Justice Archie Campbell’s Bernardo Investigation Review is released.
• February 1997: reporting to Ontario’s ViCLAS centre becomes mandatory under the Police Services Act.
• January 1, 2005: Ontario’s Major Case Management regulation takes effect for every police service in the province.
• October 2006: Joseph Edward Duncan III pleads guilty in Idaho to three counts of first-degree murder, with other charges.
• October 2006: Chile’s Supreme Court ratifies qualified life imprisonment for Julio Perez Silva.
• 2006: Washington and Idaho pass new sex offense laws after the Duncan case.
• February 25, 2008: Levi Bellfield is convicted of two murders and one attempted murder.
• November 4, 2008: California voters approve Proposition 9, Marsy’s Law.
• June 23, 2011: Bellfield is convicted of the kidnapping and murder of Milly Dowler.
• April 16, 2014: California Senate leader Darrell Steinberg seeks a review of GPS monitoring in the Gordon and Cano case.
• April 2016: Hugo Bustamante is paroled in Chile under Decree Law 321.
• December 15, 2016: Steven Dean Gordon is convicted of four counts of first-degree murder with special circumstances.
• February 3, 2017: Gordon is sentenced to death after victims' families address the court under Marsy’s Law.
• January 2019: Chile’s tightened parole law is promulgated.
• November 1, 2019: the U.S. Justice Department’s interim policy on genetic genealogy takes effect.
• June 29, 2020: Joseph James DeAngelo pleads guilty to 13 murders and 13 kidnappings.
• August 6, 2020: Bustamante is detained in the Ambar Cornejo case.
• September 24, 2020: Chile’s Senate rejects the constitutional accusation against Judge Silvana Donoso.
• March 28, 2021: Duncan dies on federal death row.
• 2021: Maryland and Montana pass laws restricting police use of consumer DNA databases.
• December 7, 2021: Bustamante is sentenced to presidio perpetuo calificado for the murder of Ambar Cornejo, with other charges.
• May 2022: Bellfield’s application to marry in prison is confirmed.
• May 10, 2023: Victoria’s Adult Parole Board refuses Denyer parole.
• June 21, 2023: Victoria’s Legislative Council defeats the opposition bill, 19 votes to 17.
• November 28, 2023: the Corrections Amendment (Parole Reform) Act 2023, Nat’s Law, passes.
• August 2, 2024: the Victims and Prisoners Act ban on marriage and civil partnership for whole life prisoners takes effect; Bellfield’s application is blocked.
• March 24, 2026: Chile publishes the decree declaring the Alto Hospicio victims' mausoleum a historic monument.
• March 2026: Chile’s Senate approves in general a bill on serving sentences outside prison.