TopLaw & Order
1990-Present
Season 6
Table of Contents
Bitter Fruit
S06E01 1995
- At the conclusion of Mrs Gaines' trial the court clerk the judge nodded to next to him who stood up and said 'the defendant will rise' is Michael Noth, the brother of Chris Noth.
- This episode appears to be based on several cases/incidents:
- The 1993 Ellie Nesler case. In 1993 Nesler shot and killed Daniel Mark Driver, a man who had been accused of child molestation after the abuse of five boys (including her then-six-year-old son, William), in the courtroom of the Jamestown Justice Court during the preliminary hearing on the charges against him.
- The 1981 Marianne Bachmeier case in Germany. In March 1981, Marianne Bachmeier opened fire in a crowded courtroom and killed Klaus Grabowski - the man on trial for murdering her 7-year-old daughter. On 2 November 1982, Marianne Bachmeier was initially charged in court with murder. Later the prosecution dropped the murder charge. After 28 days of negotiations, the Board agreed on the verdict. Four months after the opening of proceedings she was convicted on 2 March 1983 by the Circuit Court Chamber of the District Court Lübeck for manslaughter and sentenced for unlawful possession of a firearm to six years in prison but was later released after serving three years.
- The 1965 Alice Crimmins case. Crimmins was charged with killing her two children, 5-year-old Eddie Jr. and 4-year-old Alice Marie both of whom went missing on July 14, 1965. Alice Marie's body was found that day, and Eddie Jr.'s was found five days later.
- While complaining about the low image quality of the ATM camera the video tech says "the same goobers that built Hubble built this camera." She is referring to the fact that the primary mirror in the Hubble Space Telescope was ground the wrong shape due to a defective sensor that was built specifically to measure the thickness of the mirror which was the most precisely figured optical mirror ever made at the time, with a smoothness variation of less than 10 nanometers. The flawed sensor caused the mirror to be too flat around the edge by about 2,200 nanometers. This in turn led to images taken by the telescope to be out of focus, it could take images of local objects without much issue, but when it came to taking images of really bright objects like local stars, or really dim objects like distant galaxies, the images were too distorted. To-date it was the largest and most expensive blunder in NASA's history and Hubble became the butt of a lot of jokes at the time. NASA eventually found a solution, they designed special lenses to bring the light coming off the mirror back into focus, the lenses were installed during the first scheduled maintenance mission for Hubble in 1993, three years after its launch.
- Lt. Van Buren mentions that Detective Curtis has just transferred from OCCB, which stands for Organized Crime Control Bureau, a special division of the NYPD that often works with the FBI's East Coast Organized Crime Task Force. The OCCB is later featured in the spin-off series Law & Order: Organized Crime (2021), after leaving the Special Victims Unit Detective Elliot Stabler transfers to the OCCB.
- Benjamin Bratt's first episode playing the role of Detective Ray Curtis.
- John Ventimiglia has played four different roles over the course of the series:
- Danny Mastrogiorgio has played three different roles over the course of the series:
- Tom Tammi has played four different characters over the course of the series:
- How Karen Gaines got the gun in the courtroom is never revealed.
Rebels
S06E02 1995
- During the opening scene when the victim staggers out of the bar & dies, the music playing inside the bar is Lynyrd Skynyrd's "Gimme Three Steps" which is about the singer trying to get out of bar before he gets killed by his date's previous boyfriend.
- When trying on the biker jacket at the store, Claire Kincaid mentions that her boyfriend has a bike. This is likely referring to the less than obvious (at least to casual Law & Order viewer) relationship she and Jack McCoy had.
- When Briscoe and Curtis are looking at the laptop in the car, Curtis reads out, "Another non-boring night at Strokers, boys and girls, when a wannabe got in front of more torque than he could handle". Then they skip down to the last paragraph. The full text of the laptop reads [with the same caps used]: "AH! 'ANOTHER NON-BORING EVENING AT BLOTTO'S, BOYS AND GIRLS, WHEN A WANNABE GOT IN FRONT OF MORE TORQUE THAN HE COULD HANDLE TOO BAD THERE'S NO REAL DIALOGUE THAT BELONGS HERE, OTHERWISE I WOULDN'T HAVE TO WRITE IN GARBAGE CHARACTERS LIKE 'ANOTHER NON-BORING NIGHT HERE AT BLOTTOS, BOYS AND GIRLS, WHEN A WANNABE GOT IN FRONT OF MORE TORQUE THAN HE COULD HANDLE AH! 'ANOTHER NON-BORING NIGHT AT BLOTTOS, BOYS AND GIRLS, WHEN A WANNABE GOT IN FRONT OF MORE TORQUE THAN HE COULD HANDLE PLEASE IGNORE THE PRECEDING TWO PARAGRAPHS AND THE FOLLOWING THREE. GEE, THIS ROP [Prop?] TRUCK IS REMARKABLY HOT, EVER THOUGHT ABOUT INSTALLING AN AIR CONDITIONER IN HERE, RON? SO TELL ME, IS THIS A SATISFYING BUNCH OF GARBAGE TO FILL UP THE SCREEN WITH, I THINK THERE SHOULD BE ENOUGH STUFF SO THAT YOU HAVE TO SCROLL DOWN TO GET TO THE MEANINGFUL PASSAGE BY NOW. OH, HEY, I'VE GOT A GOOD IDEA, HERE'S HOW THIS WORKED OUT, RON. YOU TYPE IN THE STUFF YOU WANT TO APPEAR IN THE FAX SOFTWARE IN ANY WORD PROCESSOR. YOU THEN PRINT THIS DOCUMENT AS IF YOU WERE FAXING IT (THAT IS, WITH WINFAX PRO SELECTED AS THE PRINTER), THEN AT THE "WHERE TO FAX THE DOCUMENT" WINDOW, THERE IS A SMALL CHECKBOX IN THE LOWER RIGHT MARKED SOMETHING LIKE "SAVE FAX TO DISK". CHECK IT AND PRESS RETURN IN THE NEXT DIALOG BOX. EXIT THE WORD PROCESSOR AND RUN THE FAX VIEW PROGRAM. "OPEN" THE FILE LIKE YOU WOULD ANY OTHER. AND DADI FOUND OUT SHE SHOULD HAVE STAYED IN HER EX-OLD MAN'S BITCH SEAT. SHE HAD TO DIVE FOR COVER WHEN THE OPENER JUICED HER NEW CAGER SQUEEZE.
Savages
S06E03 1995
- In this episode, the suspect's wife mentions having "voted for Governor Pataki." The same year this episode aired (1995), Governor George Pataki did reinstate the death penalty in New York state. No one was ever put to death under the ruling, however, and in 2004, the state Court of Appeal declared the statute unconstitutional. (In this episode, the Appeals Court declines to act until after someone is actually sentenced to death under the new ruling.)
- McCoy states that 'without the death penalty there would be more Ellie Nesler's'. Ellie Nesler was a mother who, in 1993, shot and killed (in court) the man accused of sexually molesting her seven year old son (and several other children) at a Summer camp, when she discovered he had a previous conviction for the same crime but was only given probation. Nesler eventually pleaded guilty to Voluntary Manslaughter in a plea-bargain, serving three and a half years in prison. She died in 2008 aged 56.
- Amy Hohn has played four different characters over the course of the series:
- Victor Garber and Lynne Thigpen previously costarred in the 1973 movie, Godspell (1973).
- This episode appears to be based on New York's controversial capital punishment law.
- One of the characters, Judge Albert Parsons, shares his name with one of the Haymarket Trial defendants who was convicted of murder and sentenced to death.
Jeopardy
S06E04 1995
- This is the first episode in the series' history in which District Attorney Adam Schiff (Steven Hill) visits the 27th Precinct.
- This episode appears to be based on two separate cases/incidents:
- The 1989 John Merlin Taylor case.
- The 1990/1997 Harry "The Hook" Aleman case and the related suicide of Judge Frank J. Wilson. Harry Aleman was a Chicago mobster and one of the most feared mob enforcers during the 1970's in Chicago; he was suspected of murdering dozens of people. He is also famous for being the first American to be legally retried for murder after being acquitted for that same murder. He was arrested and tried for murdering the head of a trucking labor union who was causing trouble for the crime syndicate he worked for. The Chicago Circuit Court was extremely corrupt at the time, with a number of judges being on the mob's payroll. After being arrested and charged with first degree murder, Aleman requested a bench trial (a trial where the verdict is decided by a judge instead of a jury) and arranged to have the judge presiding over his case paid in exchange for acquitting him of all charges. During the 1980's, the FBI and the US Attorney's office began a thorough investigation into the rampant corruption in the Chicago Circuit Court system. This investigation revealed that the judge in Alman's case had been bribed to find him not guilty; upon learning of the investigation, the judge committed suicide. In 1993, Alman was re-indited on the murder charges he faced back in the 1970's, and his lawyer argued that the double jeopardy clause prevented his client from being retried for the same crime. The case went before the United States Court of Appeals for the Seventh Circuit, who ruled that, because the outcome of the original trial was determined before it even began, Mr. Aleman "was never truly in jeopardy since his acquittal was guaranteed by the bribe he paid to the judge". As such, double jeopardy didn't apply to this case, since technically it never attached to the case to begin with. At his second trial, in 1997, Aleman was found guilty on all counts and sentenced to 300 years in prison. This case was historic, since Aleman was the first American to be retried for murder following a fraudulent first trial.
- For the first time in the series' run, all six series regulars appear in the same scene.
- Ken Leung has portrayed three different characters in four different episodes over the course of the series:
- David Fonteno has portrayed seven different characters over the course of the series:
- John Leonard Thompson has played three different roles over the course of the series:
- Jeffrey Donovan, who appears as a murder victim, joined the show as a regular detective in seasons 21 and 22.
- Peter Frechette's girlfriend in Jeopardy (1995) is named Gaston. Frechette's character in Chinoiserie (2002) on Law & Order: Criminal Intent (2001) is also named Gaston.
- The issue of whether double jeopardy applies to cases of judicial or prosecutorial misconduct is actually something that isn't clear cut, there have been cases where some courts have ruled that double jeopardy applies even in cases of misconduct, although in general most courts have ruled that it does not apply. The most notable instance is the state of New Mexico, which has a provision in the state's constitution against double jeopardy, and in the case of State v. Hildreth (1991) the New Mexico Supreme Court ruled that the state's constitutional protection against double jeopardy prevented a defendant from being retried for the same criminal act even in cases of judicial misconduct. However there have been a number of cases where it was determined double jeopardy did not apply to cases where there was prosecutorial or judicial misconduct, since when there's misconduct on the part of the prosecution the defendant did not get a fair trial, and when it is on the part of the judge being bribed the defendant's life and liberty were never really in jeopardy. Since this episode aired there has been an even greater consensus in the courts regarding the issue, case examples of courts allowing a defendant to be retried following proof of misconduct include: the Oregon Court of Appeals in People v. Kennedy (1981), United States Court of Appeals for the Seventh Circuit in Aleman v. Judges of Cook County Circuit Court (1998), the New York Court of Appeals in People v. Mears (2009), United States Court of Appeals for the Second Circuit in United States v. Aiello (2024), and the Supreme Court of the United States in Swisher v. Brady (1978), Arizona v. Washington (1978), Oregon v. Kennedy (1982) and Bravo-Fernandez v. United States (2016).
Hot Pursuit
S06E05 1995
- This episode appears to be based on two separate cases:
- The 1974 Patty Hearst case. In 1974 Hearst was kidnapped by the left-wing terrorist organization The Symbionese Liberation Army. She was found and arrested 19 months after being abducted, by which time she was a fugitive wanted for serious crimes committed with members of the group. She was held in custody, and there was speculation before trial that her family's resources would enable her to avoid time in prison. At her trial, the prosecution suggested that Hearst had joined the Symbionese Liberation Army of her own volition. However, she testified that she had been raped and threatened with death while held captive. In 1976, she was convicted for the crime of bank robbery and sentenced to 35 years in prison, later reduced to 7 years. Her sentence was commuted by President Jimmy Carter, and she was pardoned by President Bill Clinton.
- The 1958 Caril Ann Fugate case. Fugate was the girlfriend and accomplice to spree-killer Charles Starkweather, who himself was a high school dropout and five years older than her. Caril met Charles through her older sister who was dating Charles' friend. On January 21, 1958 Caril came home from school to find that Charles had killed her parents and stabbed her sister to death. They disposed of the bodies in the barn and lived in the house together for several days, allegedly having sex with each other in the same bed Caril's sister was killed in. When family and friends became suspicious after not seeing any other members of the family for several days Charles and Caril fled, driving across Nebraska and Wyoming where they murdered six more people. They robbed a high school couple at gunpoint, stealing $4 from them, the boy and girl were both found dead later that evening with the boy being shot in the head with a .410 shotgun and the girl's body found half-naked, wearing only her bra and panties, and stabbed several times in the stomach and breasts. After being caught Charles and Caril accused each other of killing the girl, though Charles claimed credit for the other five murders. Charles was convicted on five counts of murder in the first degree and was sentenced to death, he was executed by electric chair on June 25, 1959. Right up to his execution he continued to claim credit for five of the murders but insisted that Caril killed the high school girl, some reports say he claimed her reason for killing the girl was that she was jealous because Charles commented on how beautiful the girl was. Caril continued to claim that she was innocent and didn't kill anyone, and that she was a captive of Charles and he forced her to go along with the murders. The jury in her trial did not believe her, the prosecution presented evidence that she had multiple opportunities to flee from Charles and they also presented witnesses to the fact that Charles and Caril were in love with each other. The jury found her guilty on one count of first-degree murder and five counts of accomplice to first-degree murder and sentenced her to life in prison. She is the youngest female in United States history to be tried for first-degree murder, being only 14 years old at the time of the killings. The story is the basis for the 1973 film, Badlands, starring Martin Sheen and Sissy Spacek.
- A young Amanda Peet playing the role of (Leslie) the kidnapped victim.
Paranoia
S06E06 1995
- This episode appears to be based on two separate cases/incidents:
- The 1995 Gina Grant college admissions controversy. Grant gained notoriety when her admission to Harvard College was rescinded after it became known that she had killed her mother in 1990, when she was a juvenile and omitted this fact from her college application.
- The 1995 Sinedu Tadesse case. On May 28, 1995, Tadesse stabbed her roommate Trang Phuong Ho 45 times with a hunting knife, killing her. Tadesse also attacked one of - Ho's visiting friends, a 26-year-old named Thao Nguyen, severely injuring her as well. Tadesse then hanged herself in the bathroom.
- The interplay between Lennie Briscoe and Rey Curtis in this episode strongly suggests that it was shot and originally intended to be the first episode of season 6, and the one that would introduce Rey as Lennie's new partner, replacing Mike Logan. The two detectives seem much more on tenterhooks with each other here than in the preceding five episodes of the season, with Curtis letting it slip that he checked out Briscoe's background when he found out they were to be partners, and clashing with Briscoe over when and how to question the victim's parents. Also suggestive is that Briscoe shows up solo at the crime scene during the teaser, and only meets up with Curtis in the diner after the opening credits. The writing goes a bit overboard in trying to establish Curtis as a conservative straight-arrow type, and the emphasis on his computer savoir-faire also seems like an introductory character gimmick, as well as a not-so-subtle attempt to give the new season a more "modern" feel. The overall vibe is very much that it's the first time Briscoe and Curtis are working together, and feels like a noticeable step backward from the solid professional partnership that they built over the previously aired stories (if this episode had aired before "Bitter Fruit" and "Rebels", the trajectory of their relationship would make much more sense). It's not clear why the decision would have been made to move "Paranoia" to later in the season, but sure enough, when it airs on cable, the official description on channel guides usually begins "Briscoe and his new partner...."
- Detective Lennie Briscoe attended CCNY.
- When hearing "Shelly" Kates' motion to dismiss, the Judge mentions being one of the few jurists who "believes the bloody glove should have been excluded". This is a reference to the infamous "if it doesn't fit, you must acquit" glove from the O.J. Simpson trial.
- D.A. Adam Schiff says, "Shelly' Kates could convince a jury that Jeffrey Dahmer had an eating disorder." Dahmer was a notorious serial killer who, when finally discovered by the police, was keeping the body parts of his victims in his refrigerator.
- When attempting to educate himself on the internet, Briscoe tells Van Buren he read that 100 million words are exchanged or added to the internet each day, 30 years later in 2025 internet usage has increased so much the number of words added to the internet each day is so large that it is impossible to estimate with any degree of accuracy. However there are other statistics to help show how much the internet has grown in the last 30 years: in 1995 the internet had an estimated 16 million users worldwide, with 150,500 gigabytes of data transferred per month and an estimated 2 million terabytes of data being stored online; in January there were 10,000 websites online and by December it had grown to 100,000 websites. As of March 2025 there are an estimated 5.2 billion internet users with over 100 trillion words being online and 1.2 billion websites, the amount of data on the internet has grown exponentially even in the past decade: in 2010 there was an estimated 2 zettabytes of data online (1 zettabyte is 1 billion terabytes or 1 trillion gigabytes), by 2020 that number had grown to 60 zettabytes and is expected to surpass 148 zettabytes in 2025, which is 148,000,000,000,000 gigabytes.
- Two of Detective Rey Curtis's daughters are named Olivia and Serena. Four years later Dick Wolf created Law & Order: Special Victims Unit (1999) which stars Detective Olivia Benson, who had a mother named Serena.
- ADA Kincaide mentions looking up a case on Westlaw, which is an online, subscription based legal research service available in 60 countries (as of 2024) that allows lawyers and other legal professionals to access a digital database of all published civil and criminal court cases; the company is also closely associated with the development of the internet and some of its features. Westlaw's database contains millions of legal cases, organized into 40,000 different databases covering over 400 topics and more than 98,000 legal issues. A Westlaw subscription costs between $78-$500 per month, with the exact price depending on whether the subscriber is a law firm, corporation, government entity (like a judge or federal/state prosecutor), or an individual, and depends on whether they want access to cases from just their state of residence, or all state court cases, or state & federal cases, or access to international court cases.Westlaw was founded in 1975, it was one of the very first companies outside of the U.S. government to have internal network servers that also externally connected to ARPANET (Advanced Research Projects Agency Network), the first wide-area packet-switched network to use the TCP/IP (Transmission Control Protocol/Internet Protocol) protocols and was the precursor to the modern internet; it was initially developed in the 1960's by the U.S. government to allow military installations and scientists at universities to share important data and research. Initially Westlaw was only available on dedicated terminals found in courthouses, law offices and law libraries at universities that used dial-up modems to connect to the Westlaw central server. In 1989 the first commercial internet service provider was established, with Westlaw creating one of the world's very first websites that allowed subscribers to access their servers from any desktop computer with internet access, and with certain software installed. In 1997 Westlaw created a program called Westmate, which allowed their database to be accessed from a web browser without the need for pre-installed software, it also featured one of the first advanced keyword search programs that allowed specific databases to be searched for specific words. In 2010 Westlaw created software called WestNext which allows a user to search all 40,000 of their databases simultaneously for specific keywords, while also using predictive text to suggest possible searches; many modern predictive text and keyword search programs are based on the coding used for WestNext.
- This marks the first appearance of Peter Sarsgaard in TV or film.
- Rey (Benjamin Bratt) expresses his concern over the dangerous influence of violent television shows saying he won't let his children watch network tv. A few years earlier Michael Moriarty (ADA Ben Stone) had clashed with then Attorney General, Janet Reno over the same issue and then quit the series on the grounds the producers failed to support him or free speech.
Humiliation
S06E07 1995
- Jill Hennessy's (A.D.A. Claire Kincaid) first episode as first chair on a murder trial.
- While testifying Detective Lennie Briscoe states that he doubted the victim earned $2,000 in a single night working as a prostitute, he then jokingly says "it's not like she worked for Heidi Fleiss." Heidi Fleiss is a former madam that ran a high-end prostitution ring based out of Los Angeles, California during the 1990's. She catered to the famous and wealthy and such she became known as the "Hollywood Madam."
- When Briscoe and Curtis are parked on the street waiting for the victim's pimp to show up, a hooker walks up to the car, bends down so that Curtis can look down her shirt and see her dangling breasts and tells Curtis if he likes what he sees, she would enjoy "her girls" being squeezed. Curtis replies with "what I'd like is to arrest you" and the hooker retorts with "too bad you can't arrest a girl just for asking". What she means by this is the police can't charge someone with prostitution unless they specifically offer to perform a sexual act in exchange for a specific amount of money, a woman asking a stranger to squeeze her breasts isn't breaking the law (unless she's asking a minor); and despite the common misconception, a girl showing off her breasts in public isn't against the law (in most places) since indecent exposure laws prohibit the public display of genitals, breasts & nipples aren't genitals. That's why experienced prostitutes don't ask for money right away, they flirt first both as a business tactic, if a potential customer is aroused by the sight of seeing jiggling breasts down a girl's shirt he's usually not going to be picky about the price, but also to avoid getting arrested right away.
- Robbery is when money or property is stolen by force, usually with the threat of violence, it is a more serious charge than grand larceny as it is sentenced as a violent felony, whereas grand larceny is a non-violent felony. Also with robbery the value of the property does not factor into the severity of the robbery charge, but rather the defendant's (or their accomplices') actions determine the charge; plus when someone commits the crime of robbery they are also charged with the degree of grand larceny appropriate to the value or nature of the property stolen. Robbery in the third degree is when someone forcibly steals property; it is a class D felony with a mandatory minimum sentence of 2 years in prison and a maximum of 7 years. Robbery in the second degree is when someone forcibly steals property and: 1. They're aided by another person who is an active participant, or 2. During the commission of the robbery, or in flight from the crime, they or anyone participating in the robbery: (a) Causes physical injury to another person, or (b) Displays what appears to be a firearm (this includes toy guns like Airsofts), or 3. The property stolen is a motor vehicle; it is a class C felony with a mandatory minimum sentence of 3-1/2 years in prison and a maximum of 15 years. Robbery in the first degree is when a person steals property by force and during the commission of the crime or in flight from: 1. Causes serious physical injury to another person, or 2. Is armed with a deadly weapon, or 3. Uses or threatens the imminent use a deadly weapon or dangerous instrument, or 4. Displays what appears to be a firearm and the weapon in question is in fact (as opposed to being a toy or fake): (a) A machine gun, short-barreled rifle, sawed-off shotgun, or is in possession of a silencer (regardless of whether the firearms are loaded), or (b) A pistol, revolver, rifle, shotgun or other firearm that is loaded; it is a class B felony with a mandatory minimum sentence of 5 years in prison and a maximum sentence of 25 years.
- The crimes of larceny and robbery get confused by a character, larceny is when a person steals the money or property of another person without their knowledge or presence. When the property stolen has a value of less than $1,000 the charge is petit larceny, a class A misdemeanor; whereas if the value of the property stolen is over $1,000 the charge is grand larceny, a felony with varying degrees charged depending on the nature and value of the stolen property. Grand larceny in the fourth degree is when property worth more than $1,000 is stolen, or if the stolen property (regardless of value) is stolen off the victim's person (pickpocketing), a credit card or debit card, a public or medical record, a firearm, or a motor vehicle with a value of at least $100; it is a non-violent class E felony with a sentence of two years probation and a fine of up to $1,000 or a sentence of 1-4 years in prison for prior offenders. Grand larceny in the third degree is when the value of stolen property exceeds $3,000, or the stolen property is an automated teller machine (ATM) or its contents; it is a non-violent class D felony with a sentence of 3 years probation and a fine of up to $2,000 or a prison sentence of 1-1/3 to 7 years for prior offenders. Grand larceny in the second degree is when the value of the property exceeds $50,000 or when property is stolen by means of extortion by threatening to damage the victim's property or cause them physical injury; it is a non-violent class C felony with a sentence of at least 3-1/2 years probation and a fine of $3,500, or a prison sentence of 1-1/2 to 15 years for prior offenders. Aggravated grand larceny of an automated teller machine is charged when a person steals an ATM or its contents and has previously been convicted of grand larceny; it is a non-violent class C felony. Grand larceny in the first degree is when the property stolen has a value over $1,000,000; it is a non-violent class B felony with a fine of $5,000 and a mandatory minimum sentence of 1 year in prison, for prior offenders the minimum sentence is 4-1/2 years, and a maximum sentence of 25 years.
- This episode appears to be based on the 1995 Hugh Grant/Divine Brown incident. Estella Marie Thompson, also known as Divine Brown, was a former prostitute who gained public attention on June 27, 1995, when actor Hugh Grant was caught receiving oral sex from her in his car on Hollywood's Sunset Boulevard.
- Rosa Arredondo has played four different roles over the course of the series:
- Michael McCormick has played four different roles over the course of the series:
- Patrick Boll has played four different roles over the course of the series:
Angel
S06E08 1995
- The episode appears to be based on two separate cases:
- The 1994-1995 Susan Smith case. In October 1994, she drowned her two toddlers by driving her car into a lake. She appeared on TV, sobbing, with her ex-husband, begging the African-American man who she claimed carjacked her at a stoplight to return her boys. She broke down about a week later and confessed her crime. She was sentenced to 25 years in prison. The Susan Smith case is even referenced in this episode, though not mentioned by name, when Curtis initially defends the mother in this case, saying: "You're not gonna find her baby in a car at the bottom of some lake".
- The 1968 Brewer v Williams case, in which a police officer "mentions" that he hopes the child's body is found so she can have a "Christian burial." This statement persuaded the murderer to lead the officer to where the victim's body was. This became a US Supreme Court case about Miranda warnings (of right to counsel and right to not incriminate oneself) and the validity of confessions outside of formal interrogation proceedings. A later landmark Supreme Court case, Rhode Island v Innis addressed similar issues and shares key facts with this episode.
- As mentioned before, this case has similarities with the real-life Susan Smith case. One similarity is that when Leah Coleman is addressing the TV cameras, she looks down rather than at the cameras. Susan Smith did the same thing, which is when the authorities began to suspect she wasn't telling the truth.
- When giving evidence in her defence of the murder of her baby, Leah Coleman (Elizabeth Connors) cited the horrors the world was witnessing, including the line 'terrorists are trying to blow up the World Trade Centre'. This was broadcast in November 1995 and just less than 6 years later what she was terrified of was eventually perpetrated by terrorists on 11 September 2001 (9/11).Leah Coleman was referencing the 1993 World Trade Center bombing, where a truck parked below the North Tower was set off, killing 6 people. It was intended to bring down both towers, but failed.
- Actor Fisher Stevens (Defense Attorney Ross Fineman) once again continues the tradition of an actor playing multiple characters throughout the Law & Order universe. In edition to this episode he has appeared in one episode of Homicide: Life on the Street (1993), two episodes of Law & Order: Criminal Intent (2001) and two episodes of Law & Order: Special Victims Unit (1999) playing a different character each time.
- Ray takes Leah Colman into the church where her baby allegedly was abducted from, he then talks her into admitting an incriminating statement by praying with her and asking her to consider what will happen to her daughter's soul if she isn't given a proper Christian burial. Detective Elliot Stabler from Law & Order: Special Victims Unit (1999) uses a similar tactic to get a confession from a suspect, in the season eight episode Sin (2007) Stabler and Benson were investigating the murder of a male prostitute, and their prime suspect was the pastor of a megachurch who was a strong opponent of homosexuality and frequently preached about it being an immoral act and sin, while secretly he was a closeted homosexual himself. At this point the pastor had invoked his right to counsel, Stabler went to visit the pastor in his church and like Ray did with Leah, Stabler used his faith and conscience to get the pastor to admit what he did. Stabler didn't ask the pastor any direct questions, but instead simply reminded the pastor about homosexuality and lying being sins, Stabler then began praying and asking God to forgive both his sins and the pastors, which caused the pastor to break down and confess; later in the episode a judge ruled the pastor's confession inadmissible because he deemed it to be coerced.
- Fisher Stevens' defense attorney character in this story has the same name - "Ross Fineman" - as the defense attorney played by Byron Jennings in the earlier episode Doubles (1994). Although defense lawyers often made more than one appearance during the course of the series, Stevens' character is clearly not intended to be a recurrence of Jennings' namesake attorney - besides being played by different actors, the two Ross Finemans are completely different in age, professional experience and personal style. Moreover it is indicated in this episode that Stevens' character was unknown to the DA's office prior to this case.
- Anthony Mangano has played four different characters over the course of the series:
- The opinion of the courts on the subject of using a suspect's religious beliefs to elicit a confession has varied over the decades, and the issue of whether it is violating a person's constitutional rights is a highly debated subject. The issue of police using religious beliefs to obtain a confession started to be hotly debated in the 1960's because of two different cases: the first being the 1965 case of Gessner v. U.S. in which the United States Court of Appeals for the Tenth Circuit determined "a confession induced in part by appeal to the suspect's religious inclinations was coerced"; while on the other hand in the 1966 case of Davis v. North Carolina the Fourth Circuit Court of Appeals determined that "appeal to the suspect's religious beliefs did not render a confession involuntary", in other words they determined that if a suspect voluntarily chooses to confess for no other reason than the police appealing to their conscience or beliefs then it was not coerced. More recent cases have actually been more consistent in finding that appealing to a suspect's religious beliefs is not inherently unconstitutional and any admission or confession is admissible so long as the police did not compel or persuade the suspect into confessing, or continue talking if the suspect explicitly invoked their right to remain silent. A few examples being the 2002 case of Morrison v. Florida in the Florida Supreme Court, Raymond Morrison Jr. was convicted in 1997 of murder in the first degree and sentenced to death for slitting the throat of a disabled man in a wheelchair in order to rob him, while questing him a police detective knew that Morrison was religious and brought the police department's chaplain to pray with him, during the prayer Morrison confessed to the murder. After being convicted and sentenced to death his attorney appealed the conviction to the Florida Court of Appeals who upheld it, then appealed the sentence to the Florida Supreme Court alleging his confession was coerced by using his religious views "as a weapon against him"; the Supreme Court upheld the death sentence and ruled the confession wasn't coerced because the police were not questioning him when he confessed they were simply standing there while he prayed with the chaplain. The Supreme Court of the United States recently made a similar ruling in the 2010 case of Berghuis v. Thompkins which dealt with police using questions about Thompkins' faith to elicit an incriminating statement, the court ruled against Thompkins and held that "unless and until a criminal suspect explicitly states that they are relying on their right to remain silent, their voluntary statements may be used in court and police may continue to question them".
Blood Libel
S06E09 1996
- When Det. Briscoe tells Jack McCoy that his father was Jewish but his mother wasn't and that he was raised Catholic, Jerry Orbach, who played Briscoe, is actually describing himself.
- E.A.D.A. Jack McCoy comments that "...Bill Kunstler is spinning in his grave". Kunstler was a noted lawyer who championed and represented many radical causes and clients. He died four months before this episode aired and had appeared, as himself, in White Rabbit (1994) representing a fugitive student radical whose actions had lead to the death of a police officer 23 years earlier.
- At one point Matt Hastings claims that he should have been the captain of his high school wrestling team, but fellow student Stan Shatenstein (who is not seen) was made captain instead because he is Jewish. The series later has another "Stan Shatenstein" who does appear in the flesh, in the form of an entertainingly inept Legal Aid lawyer played by actor Sig Libowitz. Atty. Shatenstein appears in the episodes Thrill (1997) and Obsession (2005), as well as in the L&O: Criminal Intent episode Tomorrow (2002).
- Roy Payne comments that he wrote a few briefs for the KKK and their march in Skokie. As of 1981 Skokie, Illinois is the home of the Illinois Holocaust Museum and Education center. But in 1977 it was the proposed site for a march by the KKK and a group of Neo Nazis. At the time the community of Skokie, a suburb of Chicago, had a population of about 70,000, 40,000 of whom were Jewish. Approximately 5,000 of the Jewish residents were survivors of the Holocaust. The residents of Skokie were shocked and outraged upon learning the news of the proposed Nazi march and filed for an emergency injunction to stop them. They filed it on the grounds that it would "incite or promote hatred against persons of Jewish faith or ancestry," that is was a "deliberate and willful attempt" to inflict severe emotional harm on the Jewish population in Skokie (and especially on the survivors of the Holocaust), and that it would incite an "uncontrollably" violent response and lead to serious "bloodshed." An injunction against the march was granted by a judge in the Cook County Circuit Court. The Neo-Nazis, in a fairly unexpected and shocking turn of events, were represented by lawyers of the ACLU, who said that while they abhorred the message the KKK and the Neo-Nazis stood for, they would represent anyone in America whose civil rights were being violated and they argued, successfully, that to prevent the KKK and the Nazis from marching would violate their First Amendment right to free speech; this case was argued before every level of court in the nation: The Cook County Circuit Court, United States District Court, Illinois Court of Appeals, United States Court of Appeals, Illinois Supreme Court and the United States Supreme Court. The ACLU filed for an emergency stay against the injunction with the United States District Court for the Northern District of Illinois, and appealed the injunction itself to the Illinois Court of Appeals and the Illinois Supreme Court and requested an expedited hearing, all three courts refused to either expedite the case or to stay the injunction. This led the ACLU to appeal the refusal by filing a writ of certiorari to the Supreme Court of the United States, with the court granting the writ and remanding the case back to the Illinois Supreme Court and ordering them to immediately grant a review of the case, stating that whenever an accusation is made that a group of people's civil rights were being violated, that accusation must be investigated without delay. The Illinois Supreme Court conducted an emergency review and remanded the case back to the Illinois Court of Appeals, the Appellate Court agreed to lift the injunction and allow the march, but also ruled that the KKK members could not wear any swastikas or other Nazi symbols or insignia. The ACLU appealed the ruling to censor the Nazi symbols to the United States Court of Appeals for the Seventh Circuit, in an en blanc decision the court ruled (6-5) in the ACLU's favor and lifted the state court's injunction against displaying Nazi symbols. The Appellate Court stated in their ruling that to censor a person(s) message simply because it was unpopular and offensive to the majority was not only a violation of their First Amendment rights, it was also a slippery slope that could lead the nation down the dark path to tyranny and oppression.
- "Kike" is an ethnic slur for a Jewish person, it is also the Hebrew word for "circle". It originated as a derogatory term for Jews on Ellis Island, which is where most of the immigrants coming into the United States were processed after World War II. Back in those days when someone who was illiterate was asked to sign their name they usually drew an "X" on forms requiring a signature, it was known as "making your mark." However most Jewish people who were illiterate made their mark with a "O" instead of an "X" which lead to the customs agents working on Ellis Island referring to Jewish immigrants as "kikes."
- ADA Kincaide says that CNN interviewed one of the jurors after the mistrial, who said that the vote was 11-1 to convict. McCoy says he wish he knew which juror had voted not guilty. However there was a way he could have known, whenever a jury has determined a verdict, or appears before the judge to deliver a report on their deliberations, both the prosecution and defense has a legal right to ask the judge to poll them. Polling a jury involves the judge asking each juror to declare what their vote is in open court, it is most commonly done after a conviction or when a jury declares a deadlock. The main reason behind jury polling is to ensure that each juror is voting of their own free will and not being influenced or coerced by other jurors or outside sources, sometimes when a jury has been deliberating a long time and there are a few holdouts the other jurors can be impatient, there have been cases where a juror has been threatened to change their vote because the others wanted to go home. By polling the jury the judge gives them an opportunity to change their mind if they are indeed being coerced or threatened. Polling a jury is also helpful in determining what course of action to take, if a jury is deliberating and only one of them is voting not guilty the defense might decide to accept a plea deal because that juror can change their mind; or if the jury is deadlocked knowing how they were voting can help the prosecution decide if they want to attempt to retry the case if/when a mistrial is declared.
- While consulting with an art expert to figure out who made the drawing depicting the murder of the teacher the expert says he knew the victim, that she brought her class to his museum on a field trip. Detective Briscoe asks him if he knows which of the students in the victim's class was most likely to be listening to "Deutschland über alles" which is German for "Germany over everything." "Deutschland über alles" is also frequently incorrectly attributed to be the title of the national anthem for Germany, the actual title being "Deutschlandlied" or "Song of Germany." Though "Deutschland über alles" is one of the lines in the first stanza of the song.
Remand
S06E10 1996
- This episode appears to be based on two separate cases/incidents: The 1964 Kitty Genovese case. This was the first widely known example of what came to be known as "the bystander effect." Kitty Genovese was a 28-year-old woman who was stabbed in front of her apartment in the early hours of March 13, 1964. The Times reported erroneously that she was stabbed within sight or earshot of 38 witnesses, none of whom tried to stop her attacker. Lacking a central number numerous calls to police were reported only a dozen had seen or heard part of the attack and none saw it in its entirety. Most believed it to be a domestic quarrel or drunken brawl, not a murder. In 2016 the Times apologized for it's flawed and grossly exaggerated report in 1964. Ten years later the term "bystander effect" was coined after 25-year-old Sandra Zahler was beaten to death on Christmas morning in her apartment overlooking the site of the Kitty Genovese murder. Only one neighbor reported hearing screams and sounds of a struggle at 3:20am but failed to do anything to help, believing the building superintendent would investigate, however the superintendent was not due to visiting family for Christmas Eve. The body was discovered by her boyfriend at 2pm the next day. The Matias Reyes (a.k.a. "The East Side Slasher") case.
- The owner of a bar tells Briscoe and Curtis he's looking to sell the place and retire, and suggests that a cop owning a bar would be a smart investment, and Briscoe mentions that he's always wanted to own a bar; which is something a few detectives from one of Law & Order's sister series does. In Homicide: Life on the Street (1993) there was a bar across the street from the Baltimore Police Department's homicide unit that was a popular police hangout, when it went up for sale Detectives John Much (Richard Belzer), Meldrick Lewis (Clark Johnson) and Tim Bayliss (Kyle Secor) agreed to buy it and go into business together. When Briscoe meets Munch and the others in the crossover episode For God and Country (1996) he mentions to Munch that there was a time he would have been envious of Munch, to which Munch replies that owning a bar isn't all its cracked up to be as they constantly have to work to remain up to date with city and county health codes, plus city and state liquor laws.
- When McCoy suggests they need to get ahead of the fact that they know who the father of Cookie's baby is by telling the jury themselves instead of the defense, he says "don't you think the L.A. prosecutors wished they had pulled the pin on the Fuhrman grenade?". McCoy is referring to the O.J. Simpson murder case, which was still being litigated when this episode was written. Mark Fuhrman was one of the LAPD detectives that investigated the murders of Nicole Brown Simpson and Ron Goldman, he was the one that discovered a crucial piece of evidence: a glove with the blood of both victims and O.J. Simpson's fingerprints on it. In 1995 Fuhrman was called to testify about his finding the glove, during cross examination Simpson's defense attorney, Johnnie L. Cochran Jr., accused Fuhrman of being a racist and planting evidence, including the glove to frame O.J.; Fuhrman denied being a racist, Cochran asked Fuhrman if he ever used racial slurs or insults which Fuhrman denied, leading Cochran to play tapes of interrogations Fuhrman had conducted with black suspects where he used a number of racial slurs and insults. Cochran, who is famous for using rhetoric to distract juries, used this to discredit Fuhrman and effectively distracted the jury (a technique called jury nullification) from the facts of the case by accusing Fuhrman of being a "bigoted Adolf Hitler worshiping racist". Fuhrman denied being a racist and claimed that his use of racial slurs was an interrogation tactic to intimidate suspects. Despite the fact that Fuhrman had never once had any complaints made against him for racism from his coworkers, and despite Cochran not having a shred of actual evidence implicating Fuhrman in planting evidence, the jury felt that Cochran impeached Fuhrman's credibility enough to create sufficient reasonable doubt to acquit Simpson. Many legal experts agree that if the prosecution had brought up Fuhrman's potential racism prior to the defense they could have mitigated the damage enough that Simpson likely would have been convicted. Even after being fired from the LAPD and charged with perjury for lying on the stand Fuhrman maintained that he did not plant any evidence.
- Talia Balsam (Teri Marks) previously played the role of Turner in Consultation (1992) (episode 3.10).
- Teri Marks files a motion to suppress Sal' Munoz's original confession because he claims the police never informed him of his rights prior to being questioned. Which is a distinct possibility, Sal was arrested in July of 1965, which was 11 months prior to the landmark decision by the Supreme Court of the United States in the case of Miranda v. Arizona, and the subsequent Miranda Warning requirement. Prior to the Supreme Court's ruling in the Miranda case the police typically did not inform a suspect of their rights prior to questioning them, usually a suspect was only informed of their rights after they had been placed under arrest; if someone was questioned by police but not arrested they were not informed of their right to remain silent, or their right to consult an attorney. The Miranda case also made it obvious that an alarming number of police officers had a woeful misunderstanding of the rights granted by the United States Constitution, especially when it came to the Fifth and Sixth Amendments. Prior to Miranda many police officers thought that the Fifth Amendment's protection against "being compelled in any criminal case to be a witness against himself" (which is what confers the right to remain silent) only applied to court proceedings, and did not realize that a person's right to remain silent included being questioned by the police. Similarly a fair number of police officers thought that the Sixth Amendment's right to legal council only applied to a criminal court proceedings, not realizing that a person's right to consult an attorney can be invoked at any point, even if someone isn't being questioned as a suspect. Another major misconception that the Miranda case helped dispel is that the rights conveyed by the Constitution apply to everyone, many people and police officers thought the Constitution's rights only applied to American citizens. The defendant in the Miranda case was an illegal immigrant named Ernesto Miranda, he was the main suspect in the Phoenix Police's investigation into the rape and murder of an 18-year old woman. He was convicted of her rape and murder in part because he confessed to the crime, however the police did not inform him of his rights prior to questioning him, or even after arresting him because the police thought he didn't have any rights as an undocumented alien. The Supreme Court vacated his conviction and remanded his case back to Arizona to be retried without his confession being allowed as evidence, although there was still sufficient evidence and he was convicted of murder a second time and sentenced to 20-30 years in prison; though he was granted parole after only five years.
Corpus Delicti
S06E11 1996
- In this episode, A.D.A. Claire Kincaid was played by Jill Hennessy's twin sister Jacqueline Hennessy for some courtroom shots which involved her sitting at the prosecutors table. She had no lines in these scenes. This was necessary because Jill was in Baltimore filming a crossover episode of Homicide: Life on the Street (1993) and did not have time to be in New York at the time this part of the episode was being filmed.
- "Corpus delicti" is Latin for "body of the crime", and refers to the legal principle that a crime must be proven to have occurred before someone can be convicted of committing the crime.
- This episode appears to be inspired by the 1977 Helen Brach case. Many elements from her disappearance (and presumed murder) in February 1977 were used in the episode. The investigation into Brach's disappearance uncovered a conspiracy to murder her to prevent her from cooperating with federal officials in Chicago investigating the horse-breeding trade. Richard Bailey, with whom Brach was romantically involved and from whom the character of Lyle Christopher is based, was the only one of the alleged conspirators to face any charges- 29 counts, including fraud and murder. He was convicted on the fraud charges and has been serving a 30-year sentence since 1995. The investigation into Brach's disappearance subsequently led to the conviction of over 50 individuals involved in the fraudulent horse trade: with charges ranging from murder, fraud, arson, and obstruction of justice. However, and unlike the episode plot, Brach's body was never found and she was legally declared dead in 1984.
- Frank Converse has played five different roles over the course of the series:
- McCoy's (possibly intentional) overzealous questioning of Lyle Christopher causes a mistrial, when preparing to retry Christopher, Schiff tells McCoy that if he intentionally caused a mistrial the judge will throw the case out. McCoy replies by saying that can only be done if there's proof he intentionally caused a mistrial, if his improper questioning was just in the heat of the moment it doesn't count. This is referring to the fact that the Supreme Court determined if a prosecutor intentionally provokes or causes a mistrial, in order to retry the defendant at a later date with better evidence, that double jeopardy would apply in that instance, but only if the prosecution intended to cause a mistrial as opposed to simply overreaching or being overzealous. Prior to this ruling prosecutors would sometimes intentionally cause a mistrial in order to do an end run around the double jeopardy clause and retry a defendant on better terms.In 1980, a man named Bruce Alan Kennedy was being tried in the Oregon Circuit Court for the Fourth Judicial District of Multnomah County on charges of theft and fraud regarding the sale of counterfeit and stolen rugs. The prosecutor was questioning an expert witness on Middle Eastern rugs, the witness said that he refused to do business with Kennedy and the prosecutor asked him if that was because Kennedy is a crook. The defense moved for a mistrial due to the prosecutor's statement being prejudicial and the judge granted the motion. When the state attempted to retry Kennedy his attorney filed a motion with the Oregon Court of Appeals to dismiss the charges on grounds of double jeopardy, alleging that the prosecutor intentionally provoked a mistrial. In State v. Kennedy (1980) the Court of Appeals ruled in Kennedy's favor dismissing the indictment, they determined that there was no evidence the prosecution intended to cause a mistrial, but that they did overreach. The Multnomah County District Attorney filed an appeal of the Appellate Court's ruling with both the Oregon Supreme Court and the Supreme Court of the United States, the appeal argued that if State v. Kennedy had determined there was no intent to cause a mistrial then double jeopardy did not apply. The United States Supreme Court agreed to hear the case, and in Oregon v. Kennedy (1982) the Supreme Court ruled against Kennedy and vacated the Oregon Court of Appeals' ruling, the Supreme Court determined that a defendant who successfully moves for a mistrial is only protected from being retried under double jeopardy if a judge or prosecutor intentionally provoked or caused a mistrial, but if the mistrial was granted simply due to overreach or overzealousness done in the heat of the moment then double jeopardy did not apply. The Supreme Court remanded the case back to the Oregon Circuit Court and Kennedy was ultimately found guilty of all charges.
- One of two horse-themed episodes featuring actor Frank Converse (the other being "Caviar Emptor").
- Joe Grifasi plays the part of James Linde in this, and two other, episodes, Previously, in Out of Control (1991) (episode 2.8), he played the role of Ezra Gould.
- Another circumstance where double jeopardy does not prevent a person from being tried twice for the same criminal act is if they can be tried in two separate sovereign courts for the same crime. Federal and state courts are considered sovereign, and therefore separate courts and jurisdictions, so it is possible for someone to face both state and federal charges for the same criminal act when it violates both state and federal law. One example is a person committing the crimes of kidnapping and murder in multiple states, if someone kidnaps a person from New Jersey and drives across the border into New York and kills them they've committed state and federal crimes, the person in question could be tried in New Jersey County Circuit Court for kidnapping, New York County Supreme Court for murder and could also be tried in the United States District Court for the Eastern District of New York on federal kidnapping and murder charges. Another example is violating both state and federal firearms laws, federal law requires firearms in all 50 states that are regulated by the National Firearms Act of 1934 and by Title II of the Gun Control Act of 1968 to be registered with the NFA Division of the Bureau of Alcohol Tobacco Firearms and Explosives; this includes firearms like machine guns, short barreled rifles with a barrel length under 16 inches or an overall length under 28 inches, sawed off shotguns with a barrel length under 18 inches or an overall length under 28 inches, firearm silencers, and destructive devices which include firearms with a bore size over 0.50 inches. Some states also have specifically outlawed possession of Title II firearms unless they are registered as required by federal law, and a few states like New York ban their possession entirely even if they were lawfully registered with the ATF. So if a person in a state that bans these weapons, or requires them to be registered, is in possession of an unregistered machine gun or short barreled rifle they would be facing both state and federal charges and a sentence of 10 years in federal prison followed by another 10 years in a state penitentiary.
- There is a misconception that double jeopardy only applies to a criminal case that has resulted in a guilty plea or verdict. However the point at which jeopardy attaches to a case is much earlier than that. In a bench trial, one where the verdict is determined by the judge, jeopardy attaches to a case the moment the first witness has been sworn in and begins testifying; in a jury trial jeopardy attaches the moment a jury has been empaneled and sworn in. At this point the defendant cannot be retried for the criminal act they are being prosecuted for even if the case is dismissed prior to a verdict, except under rare circumstances. One such circumstance is a mistrial, when the defense makes a motion for a mistrial the defendant is automatically waiving their Fifth Amendment protection against double jeopardy, and can only reassert that right if the mistrial was intentionally caused by the prosecutor or judge.
Trophy
S06E12 1996
- This episode is one of the first ones that truly start to spell out that Jack McCoy was sleeping with Claire Kincaid. It was subtly hinted at in past episodes but not explicitly stated. There were clues like in Rebels (1995) where Claire said her boyfriend rides a motorcycle...(jack does).
- This episode appears to be based on several cases/incidents:
- The 1979-1981 Atlanta child murders committed by Wayne Williams. A series of murders was committed in Atlanta, Georgia, between July 1979 and May 1981. Over the two-year period, at least 28 children, adolescents, and adults were killed by Wayne Williams, an Atlanta native who was 23 years old at the time of the last murder. He was arrested, tried, and convicted of two of the adult murders and sentenced to two consecutive life terms. Police subsequently have attributed a number of the child murders to Williams, although he has not been charged in any of those cases, and Williams himself maintains his innocence, although the killings ceased after his arrest. In March 2019, the Atlanta police, under the order of Mayor Keisha Lance Bottoms, reopened the cases in hopes that new technology will lead to a conviction for the murders that were never resolved.
- The 1971-1972 "Freeway Phantom" case. The Freeway Phantom is the pseudonym of an unidentified serial killer who murdered five girls and a woman in Washington, D.C., between April 1971 and September 1972.
- Partially ripped from the Lucio Fulci film Don't Torture a Duckling (1972).
- Isiah Whitlock Jr. played five different characters over the course of the series:
- Simon Brooks mentions the victim was "wearing the image of Justin, who was a martyr to our Lord". Saint Justin, also known as Justin Martyr and Justin the Philosopher, was an early Christian philosopher born sometime around 100 AD and was executed by the Roman Empire for sacrilege around 165 AD. Justin wrote several philosophical texts defending the morality of the Christian way of life, and denouncing the pagan gods and religions of the Roman Empire, he also passionately spoke out against the Roman persecution of Christians, writing a text with the goal of convincing Roman Emperor Antoninus Pius to abandon the persecution of the Catholic Church. For most of his life Justin traveled across Rome preaching and debating with the great philosophers of the time, shortly after Marcus Aurelius assumed the throne in 161 AD Justin moved to Rome. Justin attended a public debate with the noted philosopher Crescens the Cynic, where Justin denounced Rome's persecution of Christians, and called Marcus Aurelius a murderer for using Christians as fodder in the gladiator arenas. Crescens reported Justin to the authorities for both heresy and sacrilege, Justin along with six of his students, were tried and convicted by a Roman prefect who sentenced them to death by beheading. Justin has been venerated as a saint for over a thousand years, records of when he was first canonized have been lost to time. In 1882 Pope Leo XIII declared that April 14th would be the date of St. Justin's feast, which is the day after his day of death; since April 14th is also the date of celebrations related to Easter, the date of St. Justin's feast was moved to June 1st in 1968 by Pope John Paul VI.
- Isiah Whitlock Jr.'s character had a store named Gotham Market. In 2015 Whitlock appeared in Rogues' Gallery (2015).
Charm City
S06E13 1996
- Since 1974, Charm City was the nickname or slogan for Baltimore. At one point Charm City was the official nickname: no longer so, but unofficially and sporadically used, sometimes ironically depending on Baltimore current events. Depending on the neighborhood or event, still applicable.
- This episode appears to be based on three separate/incidents cases:
- The 1993 Colin Ferguson and the Long Island Rail Road shooting case. On December 7, 1993, a Long Island Railroad train pulled into the Merillon Avenue station in Garden City, New York, United States, when passenger Colin Ferguson pulled out a 9 mm pistol and started firing at other passengers. He murdered six people and wounded nineteen others before being wrestled to the floor of the train by three men, as he reloaded his Ruger P-89 9mm pistol for the third time, and held until the arrival of the Police. Ferguson's trial was notable for a number of unusual developments, including his firing his defense counsel and insisting on representing himself and questioning his own victims on the stand. On February 17, 1995, Ferguson was convicted of the six murders. He was also convicted of attempted murder for wounding nineteen passengers. As of 2019, he is serving his sentence of 315 years and eight months to life at the Upstate Correctional Facility in Franklin County, New York.
- The 1995 Tokyo subway sarin attack. The attack was an act of domestic terrorism perpetrated on 20 March 1995, in Tokyo, Japan, by members of the cult movement Aum Shinrikyo. In five coordinated attacks, the perpetrators released sarin on three lines of the Tokyo Metro (then part of the Tokyo subway) during rush hour, killing 12 people, severely injuring 50, and causing temporary vision problems for nearly 1,000 others. The attack was directed against trains passing through Kasumigaseki and Nagatacho, where the Diet (Japanese parliament) is headquartered in Tokyo. The group, led by Shoko Asahara, had already carried out several assassinations and terrorist attacks using sarin, including the Matsumoto sarin attack nine months earlier. They had also produced several other nerve agents, including VX, and attempted to produce botulinum toxin and had perpetrated several failed acts of bio terrorism. Asahara had been made aware of a police raid scheduled for March 22 and had planned the Tokyo subway attack in order to hinder police investigations into the cult and perhaps spark the apocalypse they believed in. The leader also wanted to start a Third World War. In the raid following the attack, police arrested many senior members of the cult. Police activity continued throughout the summer, and over 200 members were arrested, including Asahara. Thirteen of the senior Aum management were sentenced to death and later executed; many others were given prison sentences up to life. The attack remains the deadliest terrorist incident in Japan as defined by modern standards.
- The 1963 16th Street Baptist Church bombing. This was a white supremacist terrorist attack which occurred at the African-American 16th Street Baptist Church in Birmingham, Alabama, on Sunday, September 15, 1963. The bombing was committed by Thomas Edwin Blanton Jr., Herman Frank Cash, Robert Edward Chambliss, and Bobby Frank Cherry, but no prosecutions were conducted until 1977, when Robert Chambliss was tried and convicted of the first-degree murder of one of the 4 victims, 11-year-old Carol Denise McNair.
- Richard Belzer plays Detective John Munch in four crossover episodes of Law & Order (1990). He is the only actor to play the same character in crossovers from two different series. For his first three appearances on Law & Order (1990), Munch was crossing over from Homicide: Life on the Street (1993). During his fourth and final Law & Order (1990) appearance, Munch was crossing over from Law & Order: Special Victims Unit (1999).
- This is the first crossover storyline for Law & Order (1990) and Homicide: Life on the Street (1993). This crossover was unusual: while both series appeared on NBC, they did not share a common production company, producer, or writing staff, and the styles of the series differed significantly. Nonetheless, the experiment was successful enough that two more crossover stories were done in later seasons. Richard Belzer (Detective John Munch), Andre Braugher (Detective Frank Pembleton), and Kyle Secor (Detective Tim Bayliss) all play their "Homicide" characters in this episode.
- Munch was on yet another one of his rants, though this is one of the ones where he has a good point about the dangers of an extremely slow justice system. He mentions Clint Eastwood's verdict against the National Enquirer as an example, in 1983 Eastwood sued the Enquirer in California Superior Court for misusing his name & likeness in a news article and using them without permission; he also sued for slander. The magazine's lawyers used every tactic and trick in the book to attempt to delay and stall the proceedings, then filing appeals for every single decision and ruling, so much so that a final verdict was not rendered until 1997...15 years later, with the case being heard in California Superior Court, California Court of Appeals and the United States Court of Appeals! The Enquirer used Eastwood's name and image on a cover of an issue of their magazine, in a few advertisements, and also wrote an article about Eastwood having an affair with Tanya Tucker, with the article portraying the affair as a factual matter without proof. The Enquirer's attorneys argued that their use of Eastwood's name and image, and printing a story about Eastwood's affair, was Constitutionally protected under the First Amendment's clauses for free speech and freedom of the press. Eventually a judgment was made in favor of Eastwood on all accounts, ruling that use of Eastwood's name and image without consent or compensation was commercial exploitation, and that the article about his alleged affair being presented as factual was slander.In their rulings the judges all made similar statements that the free speech clause of the First Amendment does not protect speech that is not factual and is being used with the intent to slander or otherwise impugn a person's character and/or reputation; citing numerous precedents with court rulings dating back to the adoption of the Bill of Rights, including rulings by the Supreme Court. They also ruled that there are exceptions to the rights and freedoms of the press, with tabloids being the most common kind of journalism these exceptions apply to. Stating that articles about celebrity gossip like this one where unsourced and unverified allegations are made as statement of fact are not only slander but go against public interest, and therefore do not qualify as acceptable journalism and is not Constitutionally protected.
- Jordan Lage has played six different roles over the course of the series:
Custody
S06E14 1996
- First appearance of Richard Brooks (Paul Robinette) since leaving the series as a regular cast member at the end of Season 3.
- Filmed a week after New York's historic blizzard of 1996.
- When Briscoe apprehends Michael Walters, he says,"Hey, Mikey!" Later during Walters' interrogation, he says, "I don't think Mikey likes it." These are both references to Life cereal commercials. The commercials featured the slogan/catchphrase "He likes it! Hey Mikey!" The commercials aired from 1972 to 1986, the longest continuously running commercial campaign ever aired. Mikey is also how Briscoe addressed his former partner, Detective Mike Logan (Chris Noth).
- This episode's opening is atypical for the series, in that while it does take place at the site of a murder, the victim isn't shown being discovered, as is usually the case. When the teaser begins the detectives and the forensic team are already at the scene examining the body.
- McCoy mentions having a higher burden of proof to convict Jenny Mays, when compared to most kidnapping cases. This is because a person cannot be convicted of kidnapping a close blood relative if all they did was take them without any additional criminal intent; New York Penal Law Article 135, Section 30 states: "In any prosecution for kidnapping, it is an affirmative defense that (a) the defendant was a relative of the person abducted, and (b) his sole purpose was to assume control of such person". So when a parent abducts a child they cannot be automatically charged with kidnapping in second degree, a class B felony with a prison sentence of 5-25 years, but rather depending on the circumstance and the age of the person abducted they're instead charged with either: custodial interference in the second degree (class A misdemeanor), custodial interference in the first degree (class E felony), unlawful imprisonment in the second degree (class A misdemeanor) or unlawful imprisonment in the first degree (class E felony). However if a parent (or other blood relative) kidnaps a child for the purpose of holding them for ransom, physically or sexually assaulting them, or in order to accomplish the commission of a felony, they are then charged with kidnapping in the first degree, a class A-I felony with a mandatory sentence of life in prison with the possibility of parole after 15 years.
- Chuck Cooper has played five different characters over the course of the series:
- Mark Nelson has played four different roles over the course of the series:
Encore
S06E15 1996
- The first episode in which a suspect returns from a previous episode and is charged with a new crime. The first time that Michael Dobson (Larry Miller ) appeared was in Coma (1994) (episode 5.2).
- Larry Miller, who plays suspect Michael Dobson, would later play himself, comedian Larry Miller, in Smoke (2003) (episode 13.24).
- This episode appears to be based on two separate cases:
- The 1915-1919 Henri Désiré Landru (a.k.a. "The Bluebeard of Gambais") case. Landru murdered at least seven women in the village of Gambais between December 1915 and January 1919. Landru also killed at least three other women, plus a young man, at a house he rented from December 1914 to August 1915 in the town of Vernouillet, 35 km northwest of Paris. The true number of Landru's victims, whose remains were never found, was almost certainly higher.
- The 1995 Maria Isabel Pinto Monteiro Alves case. In 1995, Maria, who was jogging in Central Park and training for the New York City Marathon on September 17th of that year when she was savagely beaten. Her attacker was Aldolpho Martinez, who was a drifter who collected cans and had previous arrests, including one for rape. He had been living in an SRO not far from the site where Alves was killed. Martinez told people he'd seen Alves jogging previously and wanted to rob her Walkman music device but she didn't have it that day because it was raining heavy outside. Martinez made direct statements to multiple people to implicate himself in the murder but he died of tuberculosis in the late 1990s before he could be prosecuted.
- Nice touch having Michael Dobson ask "What happened to the other guy (Logan)?".
- Molly Price has played four different roles over the course of the series:
- Kincaide mentions the lengthy appeals process involved in death penalty cases and the fact that someone sentenced to death in 1995 would be sitting on death row well into the next century. Due to the seriousness of a capital case and the finality of the sentence, whenever a defendant is sentenced to death, there is an automatic appeal to the state's highest court, usually a state Supreme Court. In New York, the highest court in the state is the New York Court of Appeals; when someone was sentenced to death in New York City, the case is automatically reviewed by the New York Court of Appeals. If the court upheld the conviction and sentence, that was the end of the automatic appeals process. However, if the defendant so wishes, they have several other avenues of appeal in the federal court system, if they have evidence of some kind of issue, like ineffective assistance of counsel, prosecutorial or judicial misconduct, or new evidence that casts doubt on the defendant's guilt, or makes the death penalty inappropriate. If evidence of any of those is found, the defendant can file a writ of habeas corpus with the United States District Court for the Eastern District of New York; if the court denies the writ or hears the case but rules against the defendant, they can then file an appeal with the United States Court of Appeals for the Second Circuit, and their final avenue of appeal is with the Supreme Court of the United States. Since the Court of Appeals and the Supreme Court can take months to decide to hear a case and have a waiting list to hear cases that can be over a year long, it is common for a person to spend over a decade on death row before they exhaust all of their appeals.
- Luis Cruz mentions that his payment for the murder was sent to a post office box, but the "post office cops" told his girlfriend that mail held longer than 30 days would be returned. There actually is such a thing as postal police, who are known as Postal Inspectors with the United States Postal Inspection Service (USPIS), founded in 1775 they're actually the oldest federal law enforcement agency still in operation. USPIS agents are duly authorized federal law enforcement agents with jurisdiction anywhere in the United States where the Postal Service operates, postal inspectors are authorized to carry weapons, make arrests, execute federal search warrants, and serve subpoenas. Their primary jurisdiction covers any crimes that may adversely affect or fraudulently use the U.S. Mail, the postal system, or postal employees and they're also tasked with protecting the U.S. Postal Service, its infrastructure, personnel and customers. Most of the criminal investigations and arrests made by Postal Inspectors involves mail theft, in 2021 postal inspectors made 5,141 arrests leading to more than 3,700 convictions involving mail theft and mail fraud. Another major thing Postal Inspectors investigate is the mailing of illegal and prohibited items, with the most common illegally mailed items being drugs; in 2022 Postal inspectors performed over 5,300 seizures that resulted in almost 17,000 pounds of illicit drugs being taken off the streets. Prohibited items they often deal with include firearms and ammunition, which by law cannot be mailed via the postal service, but instead must be shipped via private companies like UPS, with firearms only being allowed to be shipped to and from persons who possess a dealer, pawnbroker, manufacturer or importer FFL (Federal Firearms License).Marijuana is another prohibited item that Postal Inspectors often deal with, as of 2025, 39 states have legalized medicinal marijuana, 31 states have decriminalized possession of marijuana and 24 states have legalized recreational use of marijuana; however marijuana is still regulated as a schedule I controlled substance by the federal government, and since the Postal Service is a branch of the federal government mailing marijuana is a crime, even if it is being mailed within a state that has legalized it. The Postal Service has adopted a less aggressive policy when it comes to the mailing of marijuana, they often will not arrest someone for the mailing of a misdemeanor amount, instead confiscating it and issuing a warning citation to the person mailing the package and its recipient, however repeated attempts to mail marijuana, or the mailing of a felony amount will be prosecuted.
Savior
S06E16 1996
- This episode appears to be based on two different crimes of family annihilation cases:
- The 1971/1989 John List (a.k.a. "The Boogeyman of Westfield") case. On November 9, 1971, List killed his wife, mother, and three children at their home in Westfield, New Jersey, then disappeared; he had planned the murders so meticulously that nearly a month passed before anyone suspected that anything was amiss. List became a fugitive from the law and assumed a new identity. He later remarried, and further eluded justice for nearly eighteen years. He was finally apprehended in Virginia on June 1, 1989, after the story of his murders was broadcast on the television program America's Most Wanted. After extradition to New Jersey, he was convicted on five counts of first degree murder and sentenced to five consecutive terms of life imprisonment without parole. List gave critical financial problems, as well as his perception that his family members were straying from their religious faith, as his rationale for the murders. He reasoned that killing them would assure their souls a place in Heaven, where he hoped to eventually join them. List died in prison in 2008 at the age of 82.
- The 1976 Bradford Bishop case. One of the most famous family annihilation cases in American history. State Department official Bradford Bishop killed his entire family in 1976 when he didn't receive a promotion. He then vanished. He is still on the FBI's Most Wanted Fugitives list, and he has been featured on America's Most Wanted: America Fights Back (1988) and Unsolved Mysteries (1987). As late as 2010, the FBI believed that he was still alive, likely in Europe, and that he fled the U.S. shortly after the murders using his diplomatic passport.
- Brooke Smith plays a friend of Jill Hennessy's character Claire. Both are lawyers. The two would later work together as doctors in Hennessy's show Crossing Jordan (2001).
- In this episode, Ellen Pompeo plays Jenna Weber, and Brooke Smith plays Margot Bell, Jenna's father's lawyer. They both have worked together in Grey's Anatomy (2005) as well.
- Another true crime story involving a "Family Annihilator", involved the son of Mercedes McCambridge, John Lawrence Fifield (DOB: December 25, 1941, in Hollywood, California), who was later adopted by his stepfather Fletcher Markle and took his last name. On November 16, 1987 he killed his wife, both of his children, one of which, Amy, attended Horace Mann Jr. high school, and then himself in Little Rock, Arkansas after being fired from his job from the Stephen's Inc. on November 13, 1987 for an embezzlement scheme involving accounts belonging to his mother. McCambridge's son John Markle, a UCLA graduate with a Ph.D. in Economics, joined the Little Rock, Arkansas, investment firm Stephens Inc. in 1979, after working for Salomon Brothers in New York City. Markle was a successful futures trader, and quickly rose through the company's ranks. McCambridge gave Markle $604,000 ($2.05 million) to manage for her, but in the fall of 1987, the company discovered that Markle had opened a secret account in McCambridge's name. Soon the company found that Markle had been charging trading losses to the Stephens house account, while crediting profitable trades to McCambridge's account. Markle was later shown to have forged his mother's signature in opening the account. Markle was placed on medical leave, then fired from his position at Stephens. McCambridge refused to cooperate with Markle and the company in instituting a repayment scheme that would have kept the matter from becoming public, saying that she had done nothing wrong and that Stephens Inc. owed her money. Shortly thereafter, in November 1987, Markle killed his family-his wife Christine, 45, and daughters Amy, 13, and Suzanne, 9-and then himself. He left a note taking responsibility for his crimes and a long, bitter letter to his mother. The letter contained the following: "Initially you said, 'well, we can work it out' but NO, you refused... You called me a liar, a cheat, a criminal, a bum. You said I have ruined your life... You were never around much when I needed you, so now I and my whole family are dead-so you can have the money... 'Night, Mother." In 1986, McCambridge had played the mother of a child who plans to take their own life in an Arkansas Repertory Theatre production of 'night, Mother.
- A liquor license in New York City is extremely expensive, and New York state in general has some of the highest liquor license fees in the country, with the exact cost varying by county and city. The cheapest license is a drug/grocery store beer license allowing the off premises sale of beer and malt liquor with an alcohol content of 12% or less, which costs $330 per store for two locations, a license for a third store (and each subsequent store) is $660 per location; a beer & wine license is $594 for two locations and $1,056 for each location after. A beer or wine license for on premises consumption at establishments like a restaurant is $960 in most New York counties, but in some of the more rural upstate counties it's $480. A license for off premises sale of wine is $435 in upstate counties, $960 in Buffalo and $1,920 in NYC. A liquor store license in most of New York is $1,536, in Buffalo it is $2,536 and in NYC is $4,098. The cost for an on premises liquor license for establishments like bars and hotels is $1,792 for the general state, $2,432 in Albany, $3,072 in Buffalo and $4,352 in NYC. A brewer's license starts at $2,850, is $3,600 in Albany, $4,350 in Buffalo and $5,850 in NYC. Off premises beer licenses and liquor store licenses are good for three years, wine licenses and on premises liquor licenses are good for two years and must be renewed at the same price; although first time applicants for beer and wine licenses must pay a non-refundable $100 filing fee, the filing fee for liquor and brewing licenses is $200. Additionally New York City also has a city liquor license whose cost is equal to 25% of the cost of the state license and is renewed once a year, so for example a bar or hotel that serves hard liquor would have to pay $4,352 for the state license and $1,088 for the city license, for a total fee of $6,582 every two years.
- Actress Ellen Pompeo, who plays Jenna Weber, played a character named Laura Kendrick 4 years later in Fools for Love (2000) (S10E15).
- Linda Emond has played three different characters over the course of the series:
- Ellen Pompeo (Jenna Weber) stars in Grey's Anatomy (2005). Benjamin Bratt (Detective Rey Curtis) starred in Private Practice (2007), which is a spin-off of Grey's Anatomy (2005).
- Ellen Pompeo plays Jenna Weber in this episode. Her character on Grey's Anatomy (2005) thinks of another doctor with the same last name (Richard Webber), just spelled differently, as family on that show.
Deceit
S06E17 1996
- This is a reunion of sorts for Sam Waterston (E.A.D.A. Jack McCoy) and Mary Beth Hurt (Sela Dixon) who played husband and wife in Woody Allen's movie Interiors (1978).
- Tony Conneca mentions working on a new drag routine impersonating Audrey Hepburn's best hits from Breakfast at Tiffany's (1961) and My Fair Lady (1964). The majority of the singing in those films was not actually done by Audrey, while she did the singing for the scenes where she was speaking, she did not do the singing in the film's musical numbers like "I Could Dance All Night" and "I'm Not the Girl". Her singing voice in both films was dubbed by actress and ghost singer Marni Nixon, she was also the singing voice for Deborah Kerr in The King and I (1956) and Natalie Wood in West Side Story (1961); Ms. Nixon also appeared in a season three episode of SVU Redemption (2001).
- Actor Peter Riegert (Jerold Dixon) also plays defense attorney Chauncey Zeirko on Law & Order: Special Victims Unit (1999).
- Guest actors Peter Riegert and Mary Beth Hurt, who play husband and wife in this episode, previously both appeared in the film Chilly Scenes of Winter (1979).
Atonement
S06E18 1996
- This episode appears to be based on the 1995 Linda Sobek case. Sobek was an actress and model whose career was finally taking off when she vanished. She had an upcoming role on the FOX sitcom Married... with Children (1987), but she failed to make her costume fitting. That morning, she informed her mother she was running late for a photo shoot and then departed to never come back again. A road crew worker near the Angeles National Forest was emptying trash cans in the park area when he discovered photographs of her, her date book, and a lien on a Lexus 450 SUV in her name, as she had recently been approved for a car loan and acquired said vehicle. Concerned foul play was afoot, the workman notified local police and furnished the recovered items to them. Police investigation eventually lead to photographer Charles Rathbun, who initially told police that Linda's murder was an accident, for he had accidentally struck and killed her, but this was contrary to what police already knew from her case. Her remains were found partially buried in the Angeles National Forest in California. Rathburn was convicted of her murder and sentenced to life in prison.
- Michael Imperioli appears as limo driver Johnny Stivers. He later appears in a five-episode run as Detective Nick Falco at the end of Season 15.
- The limo driver mentions dropping the victim off "at the aircraft carrier museum". The Intrepid Museum is an actual museum, located in Hell's Kitchen it was opened in 1982 and features military aircraft, vehicles, vessels and space craft; the museum's most recent acquisition is the prototype Space Shuttle Enterprise in 2012. Most of the museum is located on-board the decommissioned U.S. Navy warship USS Intrepid (CV-11), an Essex-class aircraft carrier launched in 1943 that participated in the Pacific campaigns of World War II including the assaults on the Philippines and Okinawa, Japan. After the war the Intrepid was converted to serve as an anti-submarine warfare attack carrier and carried anti-submarine aircraft equipped with sonar buoys & torpedo bombers during the Korean War and Vietnam War, the Intrepid also recovered the space capsule from the Gemini 3 mission in 1965, which was the United States' third manned mission in space; she was decommissioned in 1974 and placed in the reserve fleet, she was originally slated to be scrapped but eventually became a museum ship in 1982. The Intrepid Museum also includes the USS Growler (SSG-577), a Grayback-class cruise missile submarine launched in 1958, the Growler was one of only two submarines of this class and was an early attempt by the U.S. Navy to create a submarine primarily designed to launch cruise missiles, and was armed with the SSM-N-8 Regulus cruise missile which could be armed with either a tactical W5 nuclear warhead which was the first thermonuclear warhead and the first with an adjustable yield, which could be set between 6-120 kilotons; it also carried the larger W27 nuclear warhead with a yield of 1.9 megatons. The Regulus missiles proved to have problems in their design and were not in service long, and the Growler was retired from service in 1964 when the Navy decided to use submarine launched ballistic missiles (SLBMs) instead of cruise missiles as a nuclear deterrent since they have a much longer range.Although the Navy later revisited the concept of a cruise missile submarine, the Flight II & III versions of Los Angeles-class fast attack submarine were built with 12 vertical launch tubes and armed with Tomahawk land-attack cruise missiles & Harpoon anti-ship missiles, the Seawolf-class heavy attack submarine could launch Tomahawk cruise missiles from any of its eight torpedo tubes, and its replacement the Virginia-class cruise missile attack submarine is also equipped with 12 missile tubes. When the Strategic Arms Reduction Treaty (START) limited the number of ballistic missile submarines that could be in service the U.S. Navy also converted four of its Ohio-class ballistic missile submarines into cruise missile submarines, each of its 22 ballistic missile tubes are loaded with seven Tomahawk cruise missiles for a total of 154 missiles per submarine.
- Not yet well-known, Michael Imperioli's name is misspelled in the credits as "Michael Imperiola."
- The victim was killed after Johnny Stivers showed her a literal trunk full of cocaine, leading Frederick Scannel to order her killed so she wouldn't tell anyone about it. New York has some of the strictest drug laws in the country, enough cocaine to fill a trunk could easily result in a life sentence. In New York, possession of 10 grams or more of a controlled substance that is a stimulant (like cocaine) constitutes criminal possession of a controlled substance in the second degree, a class A-II felony (non-violent) that carries a mandatory minimum sentence of 3-8 years in prison but can carry a sentence of 10 years to life in prison for prior violent offenders; for scale 10 grams is enough to fill a suitcase. A trunk full however would constitute criminal possession of a controlled substance in the first degree, which is when someone possesses more than 8 ounces (226 grams) of a controlled substance, it is a class A-I felony with a mandatory minimum sentence of 8-20 years in prison for first-time offenders, 12-24 years in prison for a person with a prior felony drug conviction, 15-30 years for a person with a prior felony drug conviction and a prior violent felony conviction, and 20 years to life in prison for someone with two or more prior felony drug convictions and two or more prior violent felony convictions. Additionally if caught trying to sell more than 2 ounces (56 grams) of a controlled substance, a person would also be charged with criminal sale of a controlled substance in the first degree, which is also a class A-I felony with a minimum sentence of 8-20 years in prison for someone with no criminal record, 15-40 years for a prior felony drug conviction, and 25 years to life in prison for a prior felony drug conviction and violent felony conviction; this would be in addition to the possession charge, both charges together could potentially result in a sentence of life in prison with the possibility of parole after 45 years.
- Joanna Merlin (Deirdre Powell) has appeared in several Dick Wolf series. In addition to appearing in five episodes of Law & Order (1990), three of the episodes she plays defense attorney Deirdre Powell, the other two she plays defense attorney Carla Bowman. She appeared in four episodes of New York Undercover (1994) as defense attorney Carmella McNamara. She is probably best known for playing Judge Lena Petrovsky on Law & Order: Special Victims Unit (1999), Judge Petrovsky appeared in almost every season for a total of 43 episodes.
- Joanna Merlin has portrayed two different characters during the course of the series:
- Mark Lotito has played six different roles over the course of the series:
- Andrew Pang has portrayed five different characters throughout the course of the series:
- Mark Zimmerman has played five different characters over the course of the series:
Slave
S06E19 1996
- While there is no criminal statute that SPECIFICALLY prohibits a parent from selling a child, despite what McCoy and Schiff say it actually is very much illegal, especially in the circumstances under which Cassie sells her son since that is a form of slavery and forced servitude. In 1799 New York passed a law making slavery of a child illegal, and in 1827 New York became the first state in the Union to abolish slavery entirely. A parent selling their child for profit (not counting legal adoptions) is also prohibited by Article II of the New York State Constitution, ratified in 1938 it prohibits slavery, involuntary servitude, and forced labor. Even more importantly it is prohibited by the Thirteenth Amendment to the United States Constitution, which is the amendment ratified in 1865 that abolished slavery, and is enforced by 18 U.S.C. § 1590 which makes selling or owning a slave a federal crime punishable by a minimum sentence of 20 years in prison, and if the victim was kidnapped, sexually abused or there was an attempt to kill them the sentence is 30 years to life in prison; if the victim was killed the sentence is either life in prison without the possibility of parole or death. Selling a child to repay a debt would also violate federal forced labor laws at 18 U.S.C. § 1584, which makes any person who "knowingly and willfully holds to involuntary servitude or sells into any condition of involuntary servitude, any other person for any term, or brings within the United States any person so held" guilty of a class C felony with a minimum sentence of 20 years, if the victim was kidnapped or raped the defendant is guilty of a class A felony with a sentence of 30 years to life, and if the victim was murdered they face either life without parole or the death penalty.
- This episode ends with Lonnie Rickman sentenced in juvenile court, with McCoy and Kincaid silently watching the proceedings. It is a rare instance where the final scene does not contain any lines of dialogue from any of the main cast members.
- Stephen Berger has portrayed three different judges throughout the series:
- Larry Gregory has played six different roles over the course of the series:
- George Gore II also appeared in Fox's New York Undercover (1994) which was also produced by Dick Wolf.
- The actress who played Carol Merrick is uncredited but she looks like Valerie Curtin.
Girlfriends
S06E20 1996
- Enterprise corruption was a statute created to punish businesses that support or act as a front for organized crime. A person can be prosecuted for enterprise corruption if they knowingly are employed by a criminal enterprise and: 1. Intentionally participate in the criminal activity of the enterprise 2. Intentionally acquire any interest or control of an enterprise by conducting criminal activity. 3. Participate in a pattern of criminal activity and knowingly invest proceeds from the conduct into an enterprise. In order to be charged with enterprise corruption, at least three different criminal acts must be committed by an employee(s) of the corrupt enterprise and at least two of them must be felonies. Enterprise corruption is a class B felony and carries a mandatory minimum sentence of five years in prison and a maximum of 25 years. There is also the more serious charge of aggravated enterprise corruption, which is when a person commits the crime of enterprise corruption and two or more of the predicate offenses constitute violent class B or class A felonies that were committed with the use of a deadly weapon. Aggravated enterprise corruption is a class A-I felony with a mandatory sentence of life in prison with the possibility of parole after 25 years.New York's enterprise corruption laws are the state version of the federal RICO (Racketeer Influenced and Corrupt Organizations) Act. It was introduced into the Senate in January of 1970 by Arkansas Senator John L. McClellan and signed into law by President Richard Nixon in October of 1970. The RICO Act provides for extended criminal penalties and a civil cause of action for acts that violate federal law and are performed as part of an ongoing criminal organization. As of 2025, thirty-three states and territories have adopted state RICO laws, which, while being similar, also cover additional state crimes that the RICO Act doesn't include.
- When Detectives Brisoce and Curtis are questioning the second john in his pizza restaurant, Tom's Restaurant is visible across the street. Tom's Restaurant is the inspiration for Suzanne Vega's song "Tom's Diner," and its exterior was also used for the restaurant the characters frequent in Seinfeld.
- Television debut of Joelle Carter, most famously known for the character Ava Crowder in Justified (2010).
- Both Jerry Orbach and guest star James Naughton played the role of Billy Flynn in the musical 'Chicago' on Broadway. Orbach originated the role (and was nominated for a Tony Award) and Naughton won the Tony Award for a revival just over 20 years later in 1997.
- McCoy charges Barry Taggart with enterprise corruption, which is when a legitimate business organization is used as a front for, or to launder money for, a criminal organization; he mentions that Taggart has committed the two prerequisite offenses needed to charge him with enterprise corruption. In order for someone to be charged with enterprise corruption, they must commit at least two separate felonies that are related to the furtherance of a corrupt enterprise. The two felonies that Taggart committed are: promoting prostitution in the third degree, which is when a person "advances or profits from prostitution by managing, supervising, controlling, or owning...a house of prostitution or a prostitution business or enterprise involving prostitution activity by two or more persons"; promoting prostitution in the third degree is a class D felony (non-violent) with a minimum sentence of three years probation and a $2,000 fine or a prison sentence of 1-1/3 to 7 years for prior convicted felons. Taggart's second predicate felony is: hindering prosecution in the first degree, which is when a person "renders criminal assistance to a person who has committed a class A felony, or a person they know to be wanted on suspicion of committing a class A felony"; hindering prosecution in the first degree is also a class D felony. Taggart is guilty of hindering prosecution in the first degree since he helped his daughter flee the jurisdiction, knowing she had a warrant for her arrest on charges of murder in the second degree, which is a class A-I felony.
- Cara Buono has played three different roles over the course of the series:
- According to WorldCat there is no such book as "Phenomenology as Metaphor," the book Lennie picks up in the college library. The title makes no sense anyway. Such a book would not be in the same section as literature even if it existed.
- Peter Van Wagner has played four different roles over the course of the series:
- Alex Draper played three different characters over the course of the series:
- Jack Miniver uses a misogynistic slur when he is talking about the women on campus.
Pro Se
S06E21 1996
- "Pro se" is a Latin term meaning "on behalf of themselves". In legal terminology it is used to refer to a person who advocates to the court on their own behalf instead of being represented by an attorney.
- The Maginot Line was a line of concrete fortifications built by France in the 1930's the help deter invasion by Germany. When Germany finally did invade they exploited a weakness in the line, which did not extend all the way north to the English channel. The French government figured that the terrain in the Ardennes forest was too rough for a German invasion force to traverse in a fast amount of time so they never built the line that far north. The Germans were aware of this flaw and brought special equipment that allowed them to clear trees out of their path much faster than French strategists anticipated, so the vast expense put into the Maginot line was ultimately for nothing. The line has since become a metaphor for expensive efforts that offer a false sense of security, which is what Claire meant when she called the DA's office the Maginot line of the criminal justice system.
- This is one of the highest rated episodes of Law & Order at 8.8/10, second only to Aftershock (1996), which rates a 9.1/10. The third highest rated is in season 16, Invaders (2006).
- This episode appears to be based on several different cases/incidents:
- The 1986 Juan Gonzalez case.
- The 1983 Joliet, Illinois ceramic shop massacre and the related Milton Johnson (a.k.a. "The Weekend Killer") case. Johnson is a serial killer who committed up to ten known murders in Will County, Illinois between June 25 and August 25, 1983. An abundance of evidence linked him to the crimes, including the murder of two police officers. Johnson is now serving his sentence in Menard Correctional Center.
- The 1985 Sylvia Seegrist case. On October 30, 1985, Seegrist opened fire at the Springfield Mall, a shopping mall in Springfield, Delaware County, Pennsylvania, a suburb of Philadelphia. Seegrist killed three people and wounded seven others before being disarmed by a man who was shopping at the mall. The individuals killed included two men and a two-year-old boy. Seegrist was 25 years old and had been diagnosed with paranoid schizophrenia ten years earlier. Having been committed and discharged from mental care several times, her case stimulated discussion about the state's authority to commit at-risk people into mental care facilities versus individual rights.
- The Robert George Irwin (a.k.a. "The Mad Sculptor") case. Irwin was artist, sculptor, and recurring mental hospital patient who pleaded guilty to killing three people on Easter weekend in 1937 in the Beekman Hill area of New York City's Turtle Bay neighborhood.
- The 1972 -1973 Herbert Mullin case. Mullin was a serial killer who killed 13 people in California in the early 1970s. He confessed to the killings, which he claimed prevented earthquakes. In 1973, after a trial to determine whether he was legally insane or culpable, he was convicted of two murders in the first-degree and nine in the second-degree and sentenced to life imprisonment. During his imprisonment, he was denied parole eight times.
- The Jason McEnaney lawsuit related to the Ralph Tortorici case.
The 1992 Scott Panetti case. Panetti, a Texas death-row prisoner diagnosed with schizophrenia and schizoaffective disorder who believes he is at the center of a struggle between God and Satan. The state continues to insist he is competent to be executed. Panetti represented himself at his trial, appearing in court wearing a cowboy outfit and making bizarre, rambling statements. He attempted to subpoena Jesus Christ, the pope, and 200 others. He was convicted and sentenced to death. In 2007, the U.S. Supreme Court granted Panetti a rehearing on his claim that he is incompetent to be executed, saying that the state's definition of mental incompetence was too restrictive. The Court ruled that the Eighth Amendment prohibits a state from executing a prisoner whose delusional beliefs prevent him from having a rational understanding of the reasons for his execution.
- The 1987 David Riggins case. During the early hours of November 20, 1987, David Riggins went to the Nevada apartment of Paul Wade, who was later found stabbed to death. Approximately two days later, Riggins was arrested for the capital murder and robbery of Wade. After his arrest he complained of hearing voices and sleeplessness, telling the jail psychiatrist that he had taken Mellaril in the past. The psychiatrist prescribed him increasing doses of Mellaril at Riggins' request, until Riggins was taking 800 milligrams a day, considered a very high dose of that medication. Riggins was evaluated and found competent to stand trial, with one of the three evaluating psychiatrists dissenting. Riggins stated he planned to present an insanity defense and requested that the Mellaril be discontinued until after the trial so that the jury would see his mental state first hand rather than be given a false impression induced by the medication, which would deny him due process. The court heard testimony from three psychiatrists with differing opinions and then gave a one-page decision denying Riggins' request but giving no rationale for the denial. At trial, Riggins presented an insanity defense and testified on his own behalf. He indicated that, on the night of Wade's death, he used cocaine before going to Wade's apartment. Riggins admitted fighting with Wade, but claimed that Wade was trying to kill him and that voices in his head said that killing Wade would be justifiable homicide. A jury found Riggins guilty of murder with use of a deadly weapon and robbery with use of a deadly weapon. After a penalty hearing, the same jury sentenced him to death.
- Inspired by the life of John Nash and his biography A Beautiful Mind.
- Dr. Olivette mentions that it is common for patients with schizophrenia and schizoaffective disorder to stop taking their medications because when their symptoms go away, they think they are cured and no longer want to deal with the side effects. This led to the research and development of long acting formulations of antipsychotic medications that don't require daily administration and thereby prevent a patient from choosing to stop taking their medication. As of 2025 there are two first-generation antipsychotics: fluphenazine (Prolixin) & haloperidol (Haldol Decanoate) and five second-generation drugs: aripiprazole (Abilify Maintena), aripiprazole monohydrate (Abilify Asimtufii), aripiprazole lauroxil (Aristada), olanzapine (Zyprexa Relprevv) & paliperidone (Invega Sustenna) that have long acting formulations. The brand names mentioned in parenthesis are long acting injectable versions of those drugs that are injected either subcutaneously or intramuscularly. The drug is encased into a special polymer mixture that acts as a preservative and allows the drug to be gradually absorbed by the body. The exact dosing schedule varies between drugs and individual formulations, but the shortest acting ones only need to be administered every 2-4 weeks such as Prolixin & Zyprexa Relprevv; while Haldol Decanoate, Abilify Maintena, & Invega Sustenna are administered once per month; Astrida & Abilify Asimtufii only need to be administered every 6-8 weeks.
- One of two episodes where Denis O'Hare plays a defendant who represents himself in court. The other is the eighth season episode Nullification (1997).
- The severe side effects of anti-psychotic drugs are mentioned by both Dr. Olivette and James Smith, they often include difficulty concentrating, depressed mood, loss of sexual desire & sexual dysfunction, lack of energy and weight gain. James also displays another common side effect: tardive dyskinesia, a movement disorder characterized by a loss of control over voluntary muscle movements and loss of fine motor control. James is often seen blinking rapidly, jerking his head from side to side, and having spasms in his arms and hands. These movements are involuntary and can't be controlled, they're caused by the drug interfering with the function of the nervous system, and when taken long term the drugs can cause nerve damage making the condition permanent.
- Denis O'Hare has played four different characters over the course of the series.
- James Smith tells the judge he will be submitting an omnibus motion by the end of the week. Omnibus is Latin for "for everyone", and can also translate as "all together" or "all at once". As a legal term it refers to a legal request filed with the court that contains multiple distinct motions in a single document. This allows everything submitted to be considered at the same time, allowing for better efficiency and expediency. Omnibus is a term also used in bureaucracy, for example when filing multiple applications they can be submitted together to be processed at the same time, also called batch processing; for example if an employer is hiring multiple people that require background checks they can submit their background check applications as a batch to the FBI to be done at the same time, or someone planning on making or purchasing multiple Title II firearms (machine gun, short barrel rifle, silencer) in a short period can submit the required applications to the ATF as a batch so a single background check can be done for all applications at once. The term can also apply to the legislative process, an omnibus bill is one that contains multiple different proposals that are usually related, omnibus bills are usually referred to as acts; they have the advantage of allowing multiple bills to be voted on at once making for a more efficient process, but also has a downside of allowing politicians to add new bills called "riders" at the last minute, which is a sneaky tactic to get a law passed without it being given due consideration.An example of a major omnibus bill is the Violent Crime Control and Law Enforcement Act of 1994, a collection of different bills that reformed the federal criminal justice system, some for the better and some not so much. The bills included in the act were: the Federal Assault Weapons Ban that outlawed AR-15 & AK-47 style "assault" rifles in the United States for a decade, which expired in 2004 due to having a barely negligible impact on violent crime rates; the Violence Against Women Act which created numerous federal programs aimed at preventing and treating domestic violence and sexual violence against women; the Federal Death Penalty Act which created 60 new federal death penalty offenses for crimes related to acts of terrorism, non-homicidal narcotics offenses, murder of a federal law enforcement officer, civil rights-related murders, drive-by shootings resulting in death, the use of weapons of mass destruction resulting in death, and carjackings resulting in death; the Driver's Privacy Protection Act which made it illegal for a states' Department of Motor Vehicles to disclose or disseminate a person's DMV records without their written permission or a subpoena from a judge; the Jacob Wetterling Crimes Against Children and Sexually Violent Offender Registration Act which required states to create and maintain sex offender registries, which was amended by Megan's Law in 1996 requiring information in the sex offender database to be made public, and amended a second time in 2006 by the the Adam Walsh Child Protection and Safety Act which created a federal sex offender database and requires states to submit the information from their sex offender registry to the national database; the Community Oriented Policing Services which created federal funding to help city police departments hire additional officers; and the Violent Offender Incarceration and Truth-in-Sentencing Incentive Grants Program which created federal grants to state correctional facilities who required violent offenders to serve at least 85% of their sentence, created a requirement for mandatory drug testing for federal inmates on parole and created a federal three strikes law for violent felonies.
- Maryann Plunkett has portrayed three different characters over the course of the series:
- Robert Emmet Lunney played five different characters over the course of the series:
- Merwin Goldsmith plays Judge Ian Feist in this, and ten other episodes. He previously played the part of Trial Judge Gollub in Mushrooms (1991) (episode 1.17).
- Denis O'Hare and Ann Dowd play brother and sister in this episode; the pair later appeared together in Garden State (2004) though they did not share any screen time.
Homesick
S06E22 1996
- This episode appears to be based on several separate cases/incidents:
- The 1991-1992 Olivia Riner case, which is actually referenced by Schiff. Riner, a Swiss au pair, was accused by the parents of 3-month Kristie Fischer of causing the death of the infant, who died in a house fire in Thornwood, New York on December 1, 1991. Riner was found not guilty at trial because the prosecution had not provided a motive for why Riner would have started the fire.
- The Linda Lin case and the related Beech-Nut baby food product contamination panic.
- The epidemic of baby food contamination by pesticides.
- Less than 1 year after this episode first aired, British au-pair Louise Woodward was arrested in Newton, Massachusetts, over the death of 8-month old Matthew Eappen. As in this episode, Woodward had received very little training from the agency that employed her. She was convicted of second-degree murder before having her conviction reduced to involuntary manslaughter.
- Charlie Hofheimer (Ben Karmel) also played the role of Andrew Jameson in Wannabe (1995) (Episode 5.16).
- The owner of the baby food store says that the note her former employee left in the cereal box may have been racist and offensive, but it also was free speech and not illegal. Briscoe replies "Did you find out who this Patrick Henry was?". Patrick Henry was an American orator and politician, he is considered one of the Founding Fathers of the United States of America, and is best known for his speech where he spoke out against the British government's increasingly tyrannical policies that took away civil liberties, his speech ended with the famous line "give me liberty, or give me death!".Prior to the Revolutionary War, Henry was the representative of Hanover County, Virginia in the Second Virginia Convention, which aimed to create a constitution and a bill of rights for the Commonwealth of Virginia. Henry believed that war with Britain was inevitable, and predicted the Revolutionary War over a decade before it started, leading him to create legislation to establish the Virginia Militia, which would be independent of royal authority, and also create a constitutional protection for the right to bear arms; his speech proposing this legislation in 1775 is the one that contained his famous line. In 1774 he was appointed to the First Continental Congress where the first major step in the American Revolution began with the drafting of the Declaration of Independence, Henry called for the boycotting of British goods and stores, a notion inspired by a recent event in 1773 now known as the Boston Tea Party. After the Thirteen Colonies ratified the Declaration of Independence in 1776, Henry was elected the first Governor of the Commonwealth of Virginia, he served on the committee that drafted the Virginia Bill of Rights and the original Virginia Constitution, much of which is still in force today. Henry was strongly opposed to the ratification of the United States Constitution in its initial form, as it did not yet contain the Bill of Rights, which was a core part of all of the state constitutions, without a Bill of Rights he feared a federal constitution would create a central government with too much power, so he declined the offer to be a delegate to the 1787 Constitutional Convention. However his opposition to the United States Constitution largely went away after the Bill of Rights was ratified in 1791, which added the first ten Amendments to the Constitution. Henry was a strong supporter of the First Amendment, but staunchly supported the Second Amendment as it mirrored the legislation he drafted and passed for the Virginia Constitution to establish an independent state militia and guarantee the rights of the people to keep and bear arms, two things he felt are crucial to the security of a free state and for keeping the power of the federal government in check.
Aftershock
S06E23 1996
- Every episode of Law & Order opens with the investigation of a crime, usually a murder. This is the only episode that does not open with a crime or feature a criminal investigation and prosecution. This episode opens with four of the main characters witnessing the lethal injection of a prisoner--a convicted murderer--and it revolves around the characters' reactions to the execution.
- One of Jennifer Garner's first roles. She filmed the series during her first year in New York City. At the time, she was making ends meet by working as a babysitter. One of the people she babysat for was Stephen Colbert, whom she met while they both had small roles on another show.
- Len Cariou appears in this episode as Claire's old college professor. In her conversation with the professor, it is subtly revealed that he is also her stepfather.
- This is Jill Hennessy's final appearance on the show.
- Sgt. Max Greevey (George Dzundza), Assistant District Attorneys Claire Kincaid (Jill Hennessy), and Alexandra Borgia (Annie Parisse) are the only regular characters who were killed off. All the others either resigned or were transferred from their respective positions.
- This is one of the few entries of this show that doesn't deal with the investigation and prosecution of a specific case. Instead, it explores what is probably the most powerful and fate altering day in the lives of the four principals.
- This is the highest rated episode of Law & Order, as of February 2025. It's holding steady at 9.1/10 as it's a devastating and complex episode that does a lot of character development. The second highest rated episode (also in season 6) is only at 8.8/10.
- When Claire visits her old law professor he is grilling his class about two different cases dealing with the same issue where the same court ruled differently. One of his students mentions "res judicata", Latin for "a thing judged", a legal doctrine that prevents a claim or issue from being re-litigated if it has already had a final judgment rendered in civil court by a judge or jury. It is essentially the civil law counterpart to the criminal law doctrine of double jeopardy.
- The executed murders crime appears to be based on two separate cases:
- The 1964 Kitty Genovese case. On March 13, 1964, Kitty Genovese was murdered outside her apartment in Kew Gardens, Queens, New York City: no one came to help, nor did anyone call the police while she was being stabbed to death. When the police later combed the neighborhood, it was alleged that 38 people admitted to hearing her cries for help. This behavior has become known as the "bystander effect" or "Genovese syndrome." The "38 witnesses" claim was later proven to be false: further investigation many years later turned up calls from at least a dozen neighbors. It was concluded that a New York Times reporter had exaggerated some details and falsely reported others. In 2015, the Times apologized for the false story.
- The 1995 Deletha Word case. Deletha Word was a Detroit woman who in 1995 was beaten so severely by a man that she jumped off a bridge into the Detroit River to escape him even though she couldn't swim. Ms. Word drowned and her attacker was convicted of second-degree murder the following year.
- Historically lethal injections in the United States involved a three drug cocktail using: the first drug administered is sodium thiopental (Sodium Pentathol), an ultra-short acting barbiturate, often used for anesthesia and for medically induced comas, it is normally administered at a dose of 350 mg to induce anesthesia, while a dose of 5 grams (5,000 mg or 14 times the therapeutic dose) is used in lethal injections to rapidly render the inmate unconscious and stop their respiratory function; the second drug administered is pancuronium bromide (Pavulon), a non-depolarizing muscle relaxant (a paralytic agent) that is normally used to paralyze the muscles in the throat to allow for easy intubation prior to anesthesia & surgery and has a therapeutic dose of 0.07 mg to 0.1 mg/kg, for lethal injections it is used at a dose of 0.2 mg/kg (twice the maximum therapeutic dose), paralysis of respiratory muscles will lead to death in a considerably shorter time in conjunction with the barbiturate; finally potassium chloride is administered, which is an electrolyte important for proper function of the nervous system and cardiac muscles, when administered in large doses it disrupts the ability of the nerves in the heart to receive signals from the brain thereby rapidly stopping cardiac function. The sodium thiopental and potassium chloride would be lethal on their own at those dosages most of the time, but everyone has different tolerances and reactions, so multiple drugs are used to ensure a rapid and painless death.
- When Jack McCoy was sitting at a bar drinking and got chatting to the man sitting next to him, the man held up a newspaper and said 'you tell me, how come this 'Duchess of York' broad can't make ends meet; and the little kid, he's going to grow up to be King'. The Duchess of York at that time was Sarah Ferguson, who married the Queen's middle son, Prince Andrew, Duke of York. They had two female children, Beatrice and Eugenie. A daughter could not possibly have been a King. The next in line to the throne was, and still is (as of May 2022) Prince Charles, eldest son of Queen Elizabeth II and the recently deceased Prince Philip.
- Most of the pharmaceutical companies that make the drugs traditionally used for lethal injections, namely sodium pentathol and pancuronium, are located in France, Germany and the United Kingdom, where the death penalty has long since been abolished. In the late 1990's many of these companies began to refuse to export drugs for use in lethal injections, leading the United States to need a new drug cocktail for lethal injections. Several states have replaced the use of barbiturates and paralytics with benzodiazepines and opioids, while others have replaced sodium thiopental with the similar drug pentobarbital. Following this several states including Arizona, Arkansas, Kentucky, Louisiana, Oklahoma, Ohio, North Carolina and Tennessee developed a two-drug cocktail due to the shortage of barbiturates, it involved the use of 250 mg of intravenous midazolam combined with 250 mg of intramuscular hydromorphone; although as of 2025 only Arizona and Ohio have used this cocktail and both states only used it once each due to complications. In 2009 the state of Ohio developed a single drug cocktail method using 5 grams of intravenous pentobarbital, and in case there were problems with the administration of the pentobarbital (like the IV not staying in the vein) they had a secondary cocktail that consists of the intramuscular administration of 10 mg of the potent benzodiazepine midazolam, and either 450 micrograms of the ultra potent opioid sufentanil, or 40 mg of hydromorphone; on December 8, 2009, Kenneth Biros became the first person executed using Ohio's single drug method. As of 2025 seven states (Arizona, Georgia, Idaho, Missouri, Ohio, South Dakota, & Texas) have adopted Ohio's single drug method. Mississippi has developed a single drug protocol using 500 mg of hydromorphone but has yet to use it. In 2018 the state of Nebraska became the first state to use a four drug cocktail, this was the state's first lethal injection & first execution since 1997, and their first execution since the state's death penalty was reinstated by voters in 2016; previously Nebraska used the electric chair, hanging and firing squads with the inmate getting to choose which method was used. The state executed Carey Dean Moore, a double murderer convicted of killing Omaha taxi drivers Maynard Helgeland and Reuel Van Ness Jr. in 1979, he was a Son of Sam copycat; Moore was executed using diazepam (Valium) to render him unconscious, cisatracurium (a muscle relaxer), fentanyl (potent synthetic opioid) and potassium chloride to stop his heart, he was declared dead within 23 minutes.
- Madison Arnold has played five different roles over the course of the series:
- During the episode, Det. Briscoe walks into a bar with a sign saying "McSoreley's" and bumps into EADA McCoy. The only problem is that McSoreley's looks nothing like that bar shown in the episode.
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