Law & Order

Season 8

Thrill

1. This episode appears to be based on the 1997 Thomas Koskovich/Jason Vreeland murder case. On April 19, 1997, New Jersey teens Thomas Koskovich and Jayson Vreeland ordered a pizza and ambushed two men who delivered it, Georgio Gallara and Jeremy Giordano, before going bowling. Koskovich and Vreeland told police they wanted to experience what it was like to commit murder.
2. In this episode, Curtis hears the diagnosis for his wife's ailment. It is relapsing remitting MS.
3. This episode uses elements of the May 22, 1997 murder of Michael McMorrow. McMorrow was murdered by Daphne Abdela and Christopher Vasquez, a pair of teens that he had met while drinking with them in Central Park earlier that day.
4. This episode is very similar to the later Teenage Wasteland (2001) in which a group of teenagers murder a takeaway delivery man after luring him into a trap. One 18 year-old receives the death penalty.
5. Sig Libowitz, who plays legal aid attorney Stan Shatenstein, also appeared as the same character in Tomorrow (2002). During the course of the investigation Goren gets an idea, then asks Assistant District Attorney Ron Carver, "Who's the worst legal aid attorney on staff?" to which ADA Carver replies, "Stan Shatenstein". His character is then tasked with defending one of the suspects.The character makes one final appearance in Obsession (2005).
6. The detective that arrested the murder suspect when he was a teenager said that the kid was part of a gang of kids that were not very smart, so they had the nickname of "The Hole in the Head Gang." Which is a parody of the name of the gang that was led by famous outlaws Butch Cassidy and The Sundance Kid, The Hole in the Wall Gang; their name originated because they stored their stolen loot in a cave. The gang's leaders were famously portrayed by Paul Newman and Robert Redford, respectively, in Butch Cassidy and the Sundance Kid (1969).
7. Anne Lange (Headmistress) previously played the role of Evelyn Talbert in episode 5.8, Virtue (1994).
8. Reed Birney played three different characters over the course of the series:
   • Episode 2.21 Silence (1992) - Malcolm Barclay.
   • Episode 8.1 Thrill (1997) - Defense Attorney for Archdiocese.
   • Episode 20.18 Brazil (2010) - Dr. Everett Brown.
9. In addition to two other episodes of this series, actress Donna Murphy has also appeared as Congresswoman Maureen Pagolis on Albatross (2007) and Dr. Raye Massey on Retro (2008).

Denial

1. This episode appears to be based on two separate cases:
   • The 1996 Amy Grossberg and Brian Peterson case. On November 12, 1996, Grossberg, then an 18-year-old at the University of Delaware, gave birth to a baby boy in a room at the Comfort Inn in Newark, Delaware. She had hid her pregnancy from everyone but Peterson. Peterson, then an 18-year-old student at Gettysburg College and Grossberg's longtime boyfriend, delivered the child. Conflicting stories have made the subsequent events a mystery to anyone except the couple, but Peterson and Grossberg claim they believed the infant to be stillborn, wrapped him in a garbage bag, and disposed of him in a dumpster. The bloody sheets were discovered by a cleaning woman, who immediately contacted the police. After returning to school, Grossberg began to have severe seizures as a result of not having expelled the placenta. She was taken to a hospital, and it was clear to the doctors that she had just given birth. Not long after, police officials and the hospital put the two incidents together. K-9 Police dogs found the body in the dumpster.
   • The 1997 Melissa Drexler (a.k.a. "The Prom Mom") case. Drexler was a teenage high school student in 1997 who delivered her baby in a restroom stall during her high school prom dance. She put the baby in the trash can and then returned to the dance. Drexler pleaded guilty to aggravated manslaughter and was sentenced to 15 years' imprisonment. After serving three years and one month, she was released on parole.
2. This is J.K. Simmons's first appearance as Dr. Emil Skoda. Dr. Skoda appears in 45 episodes of this series and makes several appearances in New York Undercover (1994), Law & Order: Special Victims Unit (1999) and Law & Order: Criminal Intent (2001).
3. Syntocinon is the brand name for oxytocin, which is a hormone that plays an important role in emotional bonding, sexual reproduction, and labor. It is also called "the love hormone", since high levels of oxytocin are released in the brain whenever a person is experiencing the emotion of love. In women, oxytocin plays an important role in preparing the body for labor; once released, it causes the uterus and cervix to stretch and enlarge, and it also induces the muscle contractions during labor. It also plays an important role in breastfeeding and bonding, as stimulation of the nipples causes large amounts of oxytocin to be produced in the brain, and is responsible for lactation and the intimate feelings and emotions a woman experiences while breastfeeding, helping mother and child form an emotional bond. As a medication, it is used to artificially induce labor and to induce lactation in mothers who are having difficulty producing breast milk.
4. Incidents, like the one depicted in this episode, led to the New York state legislature creating and passing the Abandoned Infant Protection Act of 2000, which is known as a safe haven law. The law designated certain places, like churches, fire stations, hospitals, and police stations, as safe havens where a parent(s) could anonymously leave unwanted newborn infants, less than five days old, without fear of being prosecuted for child abandonment or neglect. The goal of the law was to reduce the number of incidents of teenage girls performing illegal and dangerous self abortions and also to reduce the rate of abandonment & murder of newborn infants. When a parent leaves their baby at one of these places, they automatically forfeit all of their legal parental rights, and the child becomes a ward of the state and is placed in foster care. In 2010, the state amended the law to extend the amount of time parents have to relinquish custody of a newborn infant to 30 days after birth; the law was also amended to allow parents who change their mind about giving up their child to get their parental rights restored within 30 days of leaving the child and, if they pass a psychological exam, to ensure they are fit to be a parent.The first state to pass a safe haven law was Texas in 1999; the previous year, the state saw 13 incidents of newborn infants being abandoned, as well as three cases of infanticide. New York became the second state to pass a safe haven law the following year. While safe haven laws are not without their downsides and controversies, they are also unquestionably successful at reducing rates of self-abortion, infanticide, and child abandonment. By 2008, all 50 states in the U.S. had passed safe haven laws. The main criticism that safe haven laws have faced has been regarding their ambiguous wording and the fact that the anonymity clause of the law favored mothers, since they were the ones most commonly making use of the law, while leaving fathers out of the loop. In their original forms, most safe haven laws automatically terminated the parental rights of both parents when the child was surrendered; this led to a number of instances where the mother would surrender a child without the knowledge or consent of the father, or vice-versa, leaving the other parent little recourse besides a lengthy and costly custody battle with the state to regain their parental rights. This is the main reason why New York, in 2010, and most other states revised the law to allow one or both parents a period of time to change their mind about giving up the child. Some states, like Nebraska, had issues with their safe haven law being too ambiguous; under Nebraska's original safe haven law, a child was defined as any person under the age of 18. After it was passed in 2008, a total of 35 children that were either pre-teens or teenagers as old as 17, were dropped off at Nebraska safe haven locations; this required the Nebraska legislature to convene an emergency session to amend the law to allow only infants less than 30 days old to be surrendered.
5. Curtis found it odd that Dr. Allan, Christina Talbert's OB/GYN, left her prescription pad sitting on her desk where someone could steal it, or steal blank sheets from it. The prescription pad that Dr. Allan had on her desk was a standard prescription pad which is used for prescribing routine medications, the kind that aren't typically abused, these standard forms can't be used for controlled substances. New York is one of the states that require physicians to use a special prescription form to prescribe controlled substances, a standard prescription form is printed on normal white paper and can be ordered from any number of vendors. New York controlled substance prescription forms on the other hand can only be obtained from the New York Bureau of Narcotic Enforcement, which is part of the New York State Department of Health, these forms are only issued to medical practitioners who possess a valid New York State Medical License, and a permit to dispense controlled substances from the DEA (Drug Enforcement Administration). A New York controlled substance prescription form has a number of security features designed to prevent the form from being photocopied or tampered with, they are printed on special chemically treated paper that will react to acids and solvents, which can be used to try and erase handwritten ink, acids and solvents will cause the paper to change color. Each form has a unique serial number printed on it and features a background comprised of a complex geometric pattern of cubes printed in blue ink, the pattern is printed in such a way as to make it difficult for most scanners and copy machines to replicate, it also has a pantograph, which is special ink that is invisible to the naked eye applied to the background, but will show up on the scanners used by copy machines, causing photocopies of the form to have the word VOID appear across the background. The form also has a large "Rx" watermark in the background that becomes visible when rubbed with a coin, a different smaller "Rx" symbol printed with thermochromic ink that will become invisible when exposed to the heat of a person's breath or friction from rubbing a finger on it. The lines for the patient's name, address, age, and the prescriber's signature & date incorporate microprinting, to the naked eye they appear as a solid line, but when viewed under a magnifying glass the lines are comprised of nearly microscopic letters that spell out the words "ORIGINAL DOCUMENT" & "AUTHENTIC DOCUMENT".
6. Jan Maxwell has played four different roles over the course of the series:
   • Episode 5.1 Second Opinion (1994) - Dr. Nancy Haas.
   • Episode 8.2 Denial (1997) - Mrs. Sarah Talbert.
   • Episode 11.3 Dissonance (2000) - Marian Reger.
   • Episode 14.7 Floater (2003) - Judge Ruth Alexander.
7. Mark Zimmerman has played five different characters over the course of the series:
   • Episode 2.17 Sisters of Mercy (1992) - Polygraph Tester.
   • Episode 3.17 Conduct Unbecoming (1993) - Mooren.
   • Episode 6.18 Atonement (1996) - Frederick Scannel.
   • Episode 8.2 Denial (1997) - Judge Nathan Murray.
   • Episode 11.15 Swept Away - A Very Special Episode (2001) - Lawyer for Gavin.
   • Episode 14.2 Bounty (2003) onwards - Judge Nathan Murphy.

Navy Blues

1. This episode appears to be based on the 1997 sex scandal involving the U.S. Air Force and Lt. Kelly Flinn. On May 20, 1997, following an adulterous affair with a civilian soccer coach at Minot Air Force Base who was married to a female enlisted subordinate in her chain of command, Flinn was charged by the military with conduct unbecoming an officer, disobeying a lawful order (in writing, to stay away from the married man), making a false official statement in which she lied under oath to Air Force investigators, falsely telling them she had ended the affair, and fraternization (for an additional affair that she had with an enlisted man). Flinn's case, due in part to her high visibility in Air Force recruitment advertisements, drew national attention, eventually creating a media circus. The Chief of Staff of the Air Force, General Ronald Fogleman, testified at a congressional hearing that: "In the end, this is not an issue of adultery. This is an issue about an officer, entrusted to fly nuclear weapons, who lied." The media, however, largely treated the case as though Flinn were being tried by the military for the crime of adultery and castigated the Air Force for allegedly firing her on moral grounds; a New York Times editorial on the case emphasized the adultery, rather than the actual military charges with which she was charged, and blamed the military's "antiquated adultery rules and their consistency in administering them, as well as their management training." Following the media outcry, Flinn was allowed to resign from the Air Force by Secretary of the Air Force Sheila Widnall with a general discharge instead of facing a court-martial. She later wrote a book recounting her experiences, entitled Proud to Be: My Life, The Air Force, The Controversy.
2. Jack Gwaltney has played three different characters over the course of the series:
   • Episode 1.8 Poison Ivy (1990) - Officer Davis
   • Episode 8.3 Navy Blues (1997) - Jack Young
   • Episode 14.3 Patient Zero (2003) - Ian Hopkins
3. Molly Price has played four different roles over the course of the series:
   • Episode 2.6 Misconception (1991) - Amy Newhouse.
   • Episode 6.15 Encore (1996) - OCCB Detective Jones.
   • Episode 8.3 Navy Blues (1997) - Quartermaster Stroud.
   • Episode 16.15 Choice of Evils (2006) - Allison Ashburn.
4. This episode aired two days after Kate Walsh's 30th birthday.
5. John Speredakos has played four different characters over the course of the series:
   • Episode 2.18 Cradle to Grave (1992) - Dr. Orton.
   • Episode 8.3 Navy Blues (1997) - William T. Ottenberg.
   • Episode 15.5 Gunplay (2004) - Bob Ardall.
   • Episode 20.23 Rubber Room (2010) - A.U.S.A. Schlicter.
6. While there has never been a USS Mendenhall, the fictional ship in this episode is named after a real person: Rear Admiral William Mendenhall. Mendenhall was an officer who served with distinction during World War II; he was a Commander with the Navy's Bureau of Ordnance when the war broke out in Europe in 1938. By 1941, he was stationed at the Naval Gun Factory in Washington D.C. which was responsible for installing and arming cruisers, destroyers & frigates with naval guns. In 1941, he was in charge of fitting out the USS Meredith (DD-434), a Gleaves-class destroyer, which he was then given command of. In 1942, he was promoted to the rank of Captain and, in 1943, was assigned to be the commander of a destroyer squadron which escorted cargo ships across the Atlantic and engaged a number of German U-boats, sinking several. In April of 1944, Mendenhall was promoted to the rank of Commodore and given command of the Anti-Submarine Warfare Unit, Fleet Operational Training Command, US Atlantic Fleet, Norfolk, Virginia; his experience proved very valuable in countering the threat of German submarines. After the war, he was assigned to the Armed Forces Special Weapons Project; in 1951, he was promoted to Rear Admiral and made the Deputy Commander of the project. Admiral Mendenhall was key in helping develop the concept of a warship armed primarily with guided missiles, and he helped create the Regulus I, which was one of the very first cruise missiles armed with a nuclear warhead. Mendenhall proposed the idea of converting some of the Navy's older battleships into guided missile battleships armed with these missiles. While these older battleships were eventually scrapped, Mendenhall was allowed to convert the surplus Boston-class cruisers from the war into the first guided missile cruisers, changing naval warfare forever. In modern naval warfare, battleships are obsolete, and guided missile cruisers and destroyers are now the most powerful surface warships, with their missiles having much longer range, accuracy and firepower than a battleship's guns. As of 2025, the most capable and heavily armed warships in the U.S. Navy are the Arleigh Burke-class guided missile destroyer and Ticonderoga-class guided missile cruiser. The most iconic American warships from World War II were the almost 900 foot long Iowa-class battleships armed with nine 16-inch guns, firing a 16 inch wide, 2,300 pound shell with an effective firing range of 24 nautical miles. The Harpoon anti-ship missiles carried by the Ticonderoga-class cruiser have a range of 75 nautical miles, and the RIM-174 Standard ERAM supersonic anti-ship missile & Block VA Tomahawk Maritime Strike anti-ship cruise missile carried on Arleigh Burke-class destroyers have a range of over 200 nautical miles. So, a battleship would be no match for a modern guided missile cruiser or destroyer; a battleship would be sunk long before its main guns were in range.
7. 'Adam Schiff' refers to Eddie Rickenbacker, when talking about how important 'Kristin Blair' is to the Navy. Rickenbacker was a WW1 flying ace, who shot down 11 enemy aircraft and was awarded the Medal of Honour. He was also a successful racing driver.
8. The murder victim's name is Robert J. Stroud. In real life, Robert F. Stroud was the "Birdman of Alcatraz". A convicted murderer serving a life sentence, he became a world famous ornithologist while in prison. The story was made into the movie Birdman of Alcatraz (1962) starring Burt Lancaster.
9. Benjamin Bratt (det.Rey Curtis) and guest star Kate Walsh (Lt. Kristin Blair) would later go on and star together in Private Practice (2007) (although, Bratt would be added to the cast in season six).

Harvest

1. When E.A.D.A. Jack McCoy and A.D.A. Jamie Ross are going through Dr. Osborne's financial records, they mention that he purchased a house in Sands Point from the widow of a judge. Although the judge is not named, this appears to be a tie-in to the season 6 episode Jeopardy (1995), which ends with Adam Schiff getting news that his old friend Judge Edgar Hynes committed suicide on the beach of his home in Sands Point.
2. This episode appears to be based on/inspired by:
   • The 1976 People v. Stewart case. In 1976, Stewart Jarvis was charged with stabbing and killing Daniel Smith. There was no doubt Stewart stabbed Smith and that Smith later died in hospital. However, at his trial, one of the principal issues was whether the stab wound caused the death or whether death was caused solely by medical malpractice at the hospital or by other intervening effective medical cause. The jury, after being asked to consider several alternative counts of assault and homicide, found the defendant guilty of manslaughter in the first degree. On his appeal, the defendant urged that the evidence was only sufficient to establish assault because the District Attorney failed, as a matter of law, to prove that the stab wound caused Smith's death beyond a reasonable doubt.
   • A piece on 60 Minutes (1968) about people being shot in Los Angeles drive-by shootings.
3. Robert Stanton has played four different roles over the course of the series:
   • Episode 2.2 The Wages of Love (1991) - Jed Knox.
   • Episode 8.4 Harvest (1997) - Jacob Sutter.
   • Episode 13.19 Seer (2003) - Tim Grayson.
   • Episode 17.2 Avatar (2006) - Douglas Preston.
4. Felix Solis has portrayed four different characters throughout the course of the series:
   • Episode 8.4 Harvest (1997) - C.S.U. Scapelli.
   • Episode 9.10 Hate (1999) - Tino.
   • Episode 16.14 Magnet (2006) - Mr. Garcia.
   • Episode 19.17 Anchors Away (2009) - Livan Santana.
5. Andrew Pang has portrayed five different characters throughout the course of the series:
   • Episode 5.17 Act of God (1995) - Mr. Kee.
   • Episode 6.18 Atonement (1996) - Mr. Nakiyama.
   • Episode 8.4 Harvest (1997) - Dr. Hsu.
   • Episode 12.2 Armed Forces (2001) - Bao.
   • Episode 20.9 For the Defense (2009) - Judge Gus Ishikawa.
6. Anthony Mangano has played four different characters over the course of the series:
   • Episode 6.8 Angel (1995) - Sluizer.
   • Episode 8.4 Harvest (1997) - Palacio.
   • Episode 13.7 Open Season (2002) - Public Officer Vitelli.
   • Episode 17.15 Melting Pot (2007) - Sal Garcetti.

Nullification

1. One of two episodes where Denis O'Hare plays a defendant who represents himself in court. The other episode was the Season 6 episode Pro Se (1996).
2. The defendants argue that the court's US flag has fringes, thereby making it a military tribunal. This is not a mistake against the show. There are anti-government groups, called Sovereign Citizens, who falsely believe such a defense. They also state any courts in the US are either military operated, or that the only courts are US Martitime or Admiralty courts. Both of which they claim the government has no jurisdiction over them.While the use of fringes on US flags is a military tradition going back to as early as 1835, it wasn't made official until 1895 for flags representing US Army regiments. Case law has stated that fringes on any US flags, including those seen in courthouses, are purely decorative. The use, or absence, of fringes does not change the flag's purpose, nor does it change the type of court in which they reside.
3. The acronym SDS stood for Students for a Democratic Society, a student activist movement in the United States during the 1960's. SDS was considered the origin for the "New Left Wing" movement. It also heavily influenced "hippie" culture as well. It's members were outspoken opponents of many of the government's policies at the time: they were vehemently against the Cold War and the nuclear arms race as well as the Vietnam War. They also criticized racial discrimination, economic inequality, big businesses, trade unions, and political parties. The SDS has also been a large influence on past and current nonviolent civil disobedience movements.
4. This episode appears to be based on several different cases/incidents:
   • The 1968 Chicago Seven case. The Chicago Seven (originally Chicago Eight, also Conspiracy Eight/Conspiracy Seven) were seven defendants-Abbie Hoffman, Jerry Rubin, David Dellinger, Tom Hayden, Rennie Davis, John Froines, and Lee Weiner-charged by the United States federal government with conspiracy, crossing state lines with intent to incite a riot, and other charges related to anti-Vietnam War and countercultural protests in Chicago, Illinois during the 1968 Democratic National Convention. The Chicago Eight became the Chicago Seven after the case against co-defendant Bobby Seale was declared a mistrial during the trial. All of the defendants were charged with and acquitted of conspiracy; Hoffman, Rubin, Dellinger, Hayden, and Davis were charged with and convicted of crossing state lines with intent to incite a riot; Froines and Weiner were charged with teaching demonstrators how to construct incendiary devices and acquitted of those charges. All of the convictions were later reversed on appeal. While the jury deliberated, Judge Julius Hoffman convicted the defendants and their attorneys for contempt of court and sentenced them to jail sentences ranging from less than three months to more than four years. These convictions were later reversed on appeal, and some were retried before a different judge.
   • The 1969-1971 Panther 21 case. The Panther 21 is a group of twenty-one Black Panther members who were arrested and accused of planned coordinated bombing and long-range rifle attacks on two police stations and an education office in New York City in 1969, who were all acquitted by a jury in May 1971, after revelations during the trial that police infiltrators played key organising roles. Among the defendants were Afeni Shakur, Lumumba Shakur, Ali Bey Hassan, Michael Tabor, Dhoruba al-Mujahid bin Wahad, Jamal Joseph, Abayama Katara, Baba Odinga, Joan Bird, Robert Collier, Sundiata Acoli, Lonnie Epps, Curtis Powell, Kuwasi Balagoon, Richard Harris, Lee Berry, Lee Roper, and Kwando Kinshasa (William King), and Thomas Berry. The trial eventually collapsed and the twenty-one members were acquitted of all charges.
   • The 1981 Brink's robbery. On October 20, 1981, six Black Liberation Army members: Mutulu Shakur, Kuwasi Balagoon, Solomon Bouines (Samuel Brown), Mtayari Shabaka Sundiata, Edward Joseph, and Cecilio "Chui" Ferguson; and four former members of the Weather Underground, now belonging to the May 19th Communist Organization, consisting of David Gilbert, Judith Alice Clark, Kathy Boudin, and Marilyn Buck stole $1.6 million in cash from a Brink's armored car at the Nanuet Mall, in Nanuet, New York. They killed Brinks guard, Peter Paige as well as seriously wounding Brinks guard Joseph Trombino and slightly wounding Brinks truck driver guard, James Kelly. Subsequently, they killed two Nyack police officers, Edward O'Grady and Waverly Brown, as well as seriously wounding Police Detective Artie Keenan.The first to be tried were Donald Weems (aka Kuwasi Balagoon) and 19 May Communists David Gilbert and Judith Alice Clark amid a heavy police presence. They represented themselves and were given three consecutive 25-year to life sentences. Weems said, "As to the 75 years in prison, I am not really worried because the State simply isn't going to last 75 or even 50 years." He died of Aids on 13 December 1986. Boudin was sentenced to 20 years to life. She was paroled in 2003. Samuel Brown was sentenced to 75 years to life. Williams was jailed for 60 years in 1988.
   • The 1997 North Hollywood shootout. On February 28, 1997, two heavily armed and armored bank robbers, Larry Phillips Jr. and Emil Matasareanu, were involved in a police shootout in the North Hollywood district of LA. Both robbers were killed, 12 police officers and eight civilians were injured, and numerous vehicles and other property were damaged or destroyed by the nearly 2,000 rounds of ammunition fired by the robbers and police.
   • The nationwide outrage of right-wing extremists following events like the Ruby Ridge standoff and the Waco siege.
   • The rise of militia organizations in the United States.
   • The purported connection between the Aryan Republican Army and the Oklahoma City bombing.
5. Denis O'Hare has played four different characters over the course of the series.
   • Episode 4.2 Volunteers (1993) - Harold Morrissey.
   • Episode 6.21 Pro Se (1996) - James Smith.
   • Episode 8.5 Nullification (1997) - Phil Christie.
   • Episode 13.12 Under God (2003) - Father Richard Hogan.
6. The firearms forensic technician mentions that one of the handguns was "filed down", illegally changing it from a semi-automatic to a fully automatic pistol. There is a component inside a Glock, and similar handguns, called a disconnector that, after the trigger has been pulled and the gun fired, prevents the firing pin from moving into the forward position to fire another shot until the trigger has been released and "resets". There are certain parts of the disconnector (for safety reasons this description is vague and the exact process is intentionally not being described) and transfer bar that when altered prevent the disconnector from doing its job, causing the firing pin to remain in the forward position turning the gun into a very crude full auto. But this kind of modification is dangerous and actually of very little use, its typically done by wanna-be gangsters who have no true understanding of how guns work and think that firing as many shots as quickly as possible is somehow more useful than firing accurately. It is dangerous because it turns the gun into what is known as a "slam fire" automatic, since the firing pin is now remaining in the forward position once the trigger is pulled the gun will continue firing until empty, even if the trigger is released. Due to the extreme muzzle jump a Glock modified in such a way is extremely inaccurate, people that have never shot a machine pistol are unprepared for the extreme amount of recoil rapid firing creates, causing them to easily shoot someone or even themselves on accident.There is one type of Glock, the Glock 18, that was designed to fire in full auto mode, it has a special auto sear installed which changes the function of the disconnector and other components and allows the gun to continue firing when the trigger is held down, but unlike a "slam fire" modified Glock will stop firing when the trigger is released. It also has a switch allowing it to fire in both semi-auto and full auto modes; however the Glock 18 is only sold to military and law enforcement, it is illegal for civilians. But with advances in 3D printing technology it has become possible for people with little to no gunsmithing experience to print a full auto sear, also called a Glock switch, when installed it convert pistols to full auto, auto sears can also be printed to convert AR-15's into full auto. 3D printers even allow people to print all the mechanisms to build a Glock from scratch. Which just goes to show that gun laws can only do so much, criminals now have more ways than ever to get their hands on guns and even make their own, there isn't ever going to be a law to prevent it, and restricting the right to bear arms is just reducing the number of armed law abiding citizens, while the number of armed criminals keeps increasing.
7. The New Sons of Liberty uses the motto "Audentes Fortuna Juvat", which is Latin for "Fortune favors the bold". This motto, and variations of it, are also used by several units in the United States military: it is the unit motto for the 366th Fighter Wing of the United States Air Force stationed at Mountain Home Air Force Base, Idaho, the 80th Fighter Squadron stationed out of Kunsan Air Base, Republic of Korea, the 3rd Battalion, 8th Marines, stationed out of Marine Corps Camp Lejeune, North Carolina, and the Seattle Police Department's SWAT unit. "Fortes Fortuna Juvat" ("Fortune helps the brave"), is the unit motto for the 2nd Battalion, 3rd Marines, stationed out of Marine Corps Base Hawaii and has been used as the motto for several vessels in the United States Navy: USNS Carl Brashear (T-AKE-7) a Lewis and Clark-class cargo ship, USS La Jolla (SSN-701) a Los Angeles-class fast attack submarine decommissioned in 2019, USS Florida (SSGN-728) a Ohio-class cruise missile submarine, USS Montpelier (SSN-765) a Los Angeles-class fast attack submarine, USS John S. McCain (DDG-56) a Flight-I Arleigh Burke-class guided missile destroyer, and is being considered as the motto for the upcoming USS Long Island (SSN-809), a Flight-V Virginia-class cruise missile attack submarine ordered in 2019 with construction slated to begin sometime in 2026. "Fortuna Favet Fortibus" ("Fortune favors the brave"), is the unit motto for the 3rd Battalion, 8th Marines, 2nd Marine Division in Hawaii.
8. When arrested Phil quotes the Second Amendment "A well regulated militia, being necessary to the security of a free state, the right of the people to keep and bear arms shall not be infringed". While its exact meaning is hotly debated, there is a general consensus in the courts that the Second Amendment's preamble grants the states the right to form militias like the National Guard, and state militias like the New York Guard and New York Naval Militia, but does not allow for private militias. Some people like Phil argues that it allows anyone to form a private, armed militia with no oversight or regulation from the government, but the United States Court of Appeals and the Supreme Court of the United States have both determined at various points in history that the "well regulated" provision establishes that only state sanctioned and regulated militias are lawful. Some have argued that the Second Amendment's right to bear arms only applies collectively to regulated state militias like the National Guard, and does not grant that right individually to the people, however most courts have strongly disagreed with that interpretation. At the time the Bill of Rights was written and ratified a state's militia could call upon any fighting age male to serve in times of need (drafting), that policy has since been limited to the regular military during times of war by both federal law, and certain interpretations of the Thirteenth Amendment. In Colonial America members of state militias were required to use their own personal firearms, including when drafted, people were expected to own and take up arms in defense of their state when called upon. As such the courts have continually agreed that the right to bear arms was intended to apply individually to the people, since at the time the people were the militia for all intents and purposes. But since when the Bill of Rights was ratified, the militia was comprised of the people, the courts have also interpreted the "well regulated" provision of the Second Amendment to also apply to the individual and not just the militia, and therefore allowing gun control laws in general to be constitutional, as long as they do not unduly burden or restrict the rights of the individual right to bear arms, unless it significantly benefits society as a whole; and so long as there is a historical precedent to base such a law on. For example there is historical precedent for restricting the rights of felons and persons who pose a danger to society to bear arms, there were laws in Colonial America that did that. Although there is no historical precedent for banning entire classes of firearms, and there is little evidence that doing so has had any kind of significant effect on reducing violent crime, which is why assault weapon bans face major constitutional issues, and will require much deliberation and consideration whenever the Supreme Court decides to finally rule on the issue.
9. Phil Christie quotes Thomas Jefferson when he says the Founding Fathers created a government that promised "life, liberty and the pursuit of happiness". This quote was used in the Declaration of Independence as three examples of the unalienable rights which the Declaration says have been given to all humans by God, and rights that all governments should protect. However this line is frequently misattributed as being part of the United States Constitution and therefore rights that enjoy constitutional protection, but it was only used in the Declaration as an idea for a basis of government, this phrase is not legally binding and is often incorrectly used by extremist groups to challenge the power and authority of the government. However the government operates by the guidelines of the United States Constitution, not the Declaration of Independence, and many of the things real life extremists like Phil protest as being illegal like taxes, arguing that taxes infringe on the liberty and happiness the Founding Fathers promised. However they forget that some of the Founding Fathers that wrote and signed the Declaration of Independence like Benjamin Franklin, also either helped write, or voted to ratify the United States Constitution, and the Bill of Rights that added the first ten Constitutional Amendments. Article I, Section 8, Clause 1 of the Constitution empowers Congress to "lay and collect Taxes, Duties, Imposts and Excises"; without taxes there would be no government at all, and no military or law enforcement to defend people's liberty. While the protection of life and liberty is the goal of many of the Constitution's rights, they of course are not absolute either, the Fifth Amendment grants the government the right to deprive people of both life and liberty so long as it is done by due process of law and on an indictment by a grand jury, both of which require decisions made by juries comprised of the people.
10. Mr. Shelby, one of the jurors, is played by actor Walt MacPherson. He also plays Detective/Captain Roger Gaffney on Law & Order's sister series Homicide: Life on the Street (1993). Homicide has had several crossover episodes with Law & Order, it is also the series that the character of Detective John Munch (Richard Belzer) originally appeared on, before becoming a character on Law & Order: Special Victims Unit (1999).
11. The MAC-11 is a machine pistol manufactured by Military Armament Corporation, it is a select fire weapon capable of firing in both semi-automatic and fully automatic modes, and is chambered for either 9x19mm Parabellum or .380 ACP. It is designed for use by the military, law enforcement and private security contractors for close quarters engagements, it is often carried by protection details because it is light and concealable while still offering a lot of firepower; U.S. Secret Service agents often carry the MAC-11, and the larger MAC-10 chambered in .45 ACP, when escorting the President in areas where there is close contract with crowds. A civilian-legal semi-automatic version is made, as the forensic tech points out these can be illegally modified to become fully automatic. Some of the older full auto MAC-10's and MAC-11's are legal for civilians to use since they were first manufactured in 1972, they are actually one of the most commonly owned civilian machine guns, it is extremely rare for them to be used in crimes due to their strict regulation and high cost, most MAC machine pistols use in crimes are either military issued ones sold on the black market or illegally modified semi-autos.
12. Machine guns are regulated by the National Firearms Act of 1934, Title II of the Gun Control Act of 1968, and the Firearm Owners Protection Act of 1986, along with short barreled rifles (SBR) with a barrel under 16 inches, short barreled shotguns (SBS) with a barrel under 18 inches, destructive devices with a bore size over .50 inches, and firearm suppressors (inaccurately called silencers); in order to legally possess one of these firearms a person must submit an application to the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) with their name, address, date of birth, Social Security number, fingerprints & a passport-style photo, the application also must include the make, model and serial number of the firearm, pay a $200 tax stamp, and notify the chief law enforcement officer in their area. After the ATF conducts an enhanced background check used to take several months to a year, that has been reduced to a few weeks since the ATF began accepting electronic applications in 2022, a person can then purchase one of these firearms form a licensed dealer. Because of the high amount of regulations it is extremely rare for lawfully owned machine guns to be used in crimes, 99% of machine guns used by criminals are illegally obtained from other countries, illegally modified semi-autos, or homemade. After the Firearm Owners Protection Act of 1986 was passed the number of machine guns that civilians can legally own became heavily limited, the act prohibited the sale, transfer or possession of a machine gun by civilians if the machine gun was manufactured after 1986; this was done as a compromise to appease legislators that wanted to entirely ban machine guns, but they were sold on the post-86 machine gun ban because of the data showing that the NFA registration requirements work to prevent civilian owned machine guns from being used by or sold to criminals. This has significantly driven up the cost of machine guns manufactured prior to 1986, a pre-86 MAC-10 or MAC-11 costs between $10,000-$12,000, burst fire M16's usually sell for around $15-20,000, and a full auto M16A2 can easily sell for over $30,000.Although there are eight states: California, Delaware, Hawaii, Illinois, Massachusetts, New Jersey, New York, Rhode Island and Washington D.C. where most or all Title II firearms are illegal, even if they are registered with the ATF in compliance with federal law.
13. In 2013 the state of New York passed the SAFE Act which banned most Title II firearms including machine guns, SBR's, SBS's, and firearm suppressors, including ones lawfully registered with the ATF. It also banned assault weapons like the AR-15 and AK-47, and any semi-automatic rifle with features such as a vertical forward grip, telescoping stock, threaded barrel, pistol grip and banned magazines with a capacity greater than 10 rounds. As of 2024 there is a lawsuit pending with the Supreme Court of the United States challenging the ban of Title II weapons on grounds of violating the Second Amendment, the lawsuit argues that there is no compelling public interest to justify banning lawfully registered Title II firearms, since as of that year in the U.S. there are 146,098 registered short-barreled shotguns, 532,000 registered short-barreled rifles, 741,146 registered machine guns, and 4.9 million lawfully registered suppressors; ATF crime reports showed that only 44 registered suppressors (0.003%) have been used in crimes in the previous 10 years, 21 SBR's & SBS's (0.0015%), and only one registered machine gun has been used in a criminal act since 1934. There are also lawsuits pending in both the United States Court of Appeals and the Supreme Court challenging the assault weapon and magazine ban because of how easily criminals can circumvent those laws, and because there are an estimated 44 million lawfully owned AR-15's in the US, and over 110 million lawfully owned rifles, while an average of only 314 rifles (0.0000029%) are used in violent crime each year, compared with 1,544 knives each year. These lawsuits follow on the heels of the Supreme Court's landmark ruling in the case of New York State Rifle & Pistol Association, Inc. v. Bruen (2022), in a 6-3 ruling the Supreme Court determined that the New York State Police's policy of requiring applicants for a concealed handgun license to show cause, known as a "may issue" policy", to be unconstitutional and violated the Second Amendment's right to bear arms. In Bruen, as well as the Heller case in 2008, the Supreme Court established a two-part balancing test in regards to restricting the ownership or use of a firearm: 1: is the firearm in question in common use for lawful purposes and 2: is there a compelling public interest in restricting an individual's right to bear said arm. In Bruen the Supreme Court found that New York's may issue policy failed both tests, handguns by far are the most commonly used firearm for lawful purposes, and only law abiding citizens undergo the time consuming, and expensive process, of obtaining a concealed carry permit, and violent crimes are very rarely committed by those with carry permits. The court ordered that all states from then on would be required to have a "shall issue" policy for carry permits and issue them to any person who qualifies to own a handgun under state and federal law.
14. At the time this episode takes place, summer of 1997, the Federal Assault Weapons ban was in effect. Passed in 1994 it banned the manufacture, sale and transfer of AR-15 and AK-47 rifles (and their variants) for civilians, although it did not ban possession of these rifles, so long as someone could prove they lawfully purchased it prior to the ban taking effect. The ban was part social policy, and part social experiment, to determine stricter gun law effects on gun violence and violent crime in general. As such it had a sunset provision that caused the ban to expire after 10 years, and could only be renewed by a vote from the Senate if there was evidence the ban had a significant effect on lowering crime rates. The ban was allowed to expire in 2004 because it had no definitive effect on violent crimes, during the 10 year period there was a minor reduction (16%) of mass shootings, but overall violent crime rates increased, and the change in mass shooting rates was too small to be attributed to the ban. In fact crime statistics gathered as part of the ban's study showed that the majority of violent crimes where a weapon was used, involved the use of handguns and knives. Critics of the ban being allowed to expire feared that the streets would be flooded with assault weapons and that violent crime rates would skyrocket. However that has not been the case, at least the latter part, when the ban went into effect there were an estimated 1 million civilian owned assault rifles in the United States, in 2019 that number has increased to an estimated 40 million, while the number of rifles used in violent crimes each year averages around 350, a very, very small percentage; especially considering that at least half were not lawfully purchased firearms.

Baby, It's You

1. The story-line of this episode (Episode 8.6) is concluded in an episode of "Homicide" (Baby, It's You (1997), Episode 6.5). Jerry Orbach (Detective Lennie Briscoe), Sam Waterston (EADA Jack McCoy), Benjamin Bratt (Detective Rey Curtis), and Carey Lowell (ADA Jamie Ross) all play their "Law & Order" characters in the "Homicide" episode. Also, Richard Belzer (Detective John Munch), Yaphet Kotto (Lt. Al Giardello), Jon Seda (Detective Paul Falsone), and Zeljko Ivanek (ASA Ed Danvers) appear again in the "Homicide" episode. Unfortunately, in "Law & Order" syndication presentations, the continuation episode is usually not broadcast. Law & Order proceeds to the next Law & Order episode, Blood (1997). Also, the Law & Order syndication presentations provide no on-screen information that the episode's story-line continues in Homicide: Life on the Street (1993). This Law & Order episode ends with McCoy mentioning prosecuting Janaway and Skoda telling McCoy about child sexual predators. An extended black screen is seen prior to Dick Wolf's producer credit being displayed. In this spot, the original airing indicated the episode would continue in the "Homicide" series. In the L&O Season 8 DVD set, Homicide: Life on the Street: Baby, It's You is included as a bonus feature for continuity.
2. This episode features a Bond girl and a Bond villain: Carey Lowell (Jamie Ross) played Pam Bouvier in Licence to Kill (1989), while Yaphet Kotto (Al Giardello) played Dr. Kananga (Mr. Big) in Live and Let Die (1973).
3. The police's investigation and the DA's case are jeopardized by the details of the girl's death (specifically her being raped) being leaked to the media and then published by them. Such a practice is one of the main reasons for the creation of the Rape Shield Law, which makes it illegal for the media to publish the name or photo of a rape victim. It also prevents a rape victim's prior sexual history being introduced at trial (except in a few specific circumstances) because such information is irrelevant to the victim's getting raped. For example, the defense might try to suggest that the victim was "easy" because she had had multiple sexual partners or that she was "asking for it" because she had led the perpetrator on by dressing or acting provocatively. This defense tactic sometimes works because juries sometimes forget that the law states a person has the right to say no and stop a sexual encounter at any point, even if sexual intercourse has begun. By limiting the kind of evidence the defense is allowed to mention about the victim's previous sexual partners or about his/her sexual preferences, the rape shield law helps to ensure that juries base their verdict on the law, not on their own opinions about whether the victim's sexual practices or orientation are immoral. It also helps rape victims come forward and report the crime because victims don't have to be afraid of knowledge about their being raped or the details of the crime being released to the public and causing embarrassment for the victim and their family.
4. This episode appears to be based on the JonBenét Ramsey case.
5. Tom Tammi has played four different characters over the course of the series:
   • Episode 2.10 Heaven (1991) - James Collins.
   • Episode 6.1 Bitter Fruit (1995) - Mr. Gaines.
   • Episode 8.6 Baby, It's You (1997) - Dr. Steven Janaway.
   • Episode 12.4 Soldier of Fortune (2001) - FBI Agent Frank Gilliam.
6. Jon Seda would go on to star in the Dick Wolf created series Chicago P.D. (2014) as a detective.
7. This episode takes place in October 1997.
8. When asked about the volatile fashion designer for whom the victim worked, her agent sarcastically says "too bad he wasn't in South Beach last summer to catch a bullet," referring to the murder of Gianni Versace, who was shot by serial killer Andrew Cunanan in July 1997, four months before the episode aired.

Blood

1. Adam Schiff's quote "Back then they had lynch mobs and bull-whips; now they use toilet plungers" is a reference to the beating and sexual assault of Abner Louima at the hands of the NYPD. The case made national news in August 1997, a few months before this episode first aired.On August 9, 1997, Haitian immigrant Abner Louima was arrested outside a nightclub in Brooklyn. Responding officers Thomas Bruder, Charles Schwarz, Justin Volpe, and Thomas Wiese viciously beat Louima during the ride to the precinct with their nightsticks, radios, and fists.Once Louima was in a holding cell, he was stripped naked and searched, then the beating resumed. Louima was cuffed and led to a bathroom where Volpe forcibly sodomized him with a broken broomstick. Volpe then jammed the broomstick into his mouth, breaking several of his teeth.Louima was hospitalized for 2 months following the brutal attacks and required three surgeries to repair the damage wrought by the officers.
   • Volpe initially pleaded not guilty but was convicted in 1999 of the charges and sentenced to 30 years in prison and ordered to pay $277,495 restitution and a $525 fine
   • Schwarz was convicted in 2000 and sentenced to 15 years in prison
   • Bruder, Wiese, and another officer, Sergeant Michael Bellomo were indicted for trying to cover up the brutal sexual and physical assault. They were initially convicted, but this was overturned by a federal judge in 2002.
2. This episode appears to be based on the following: The life of Anatole Broyard, a light-skinned man born to a Black Louisiana Creole couple. Anatole and his older sister had light skin and "European" features, whereas his younger sister had dark skin. He experienced constant bullying as a child; the white children wouldn't play with him because they knew he and his family were black, and the black children wouldn't associate with him because he looked white. Anatole saw his light-skinned parents "pass" as white and decided to do the same thing in order to avoid discrimination. When he joined the military, he was categorized as white during enlistment, and he received promotions that would have been denied to him if they knew he was Black. He attained the rank of Captain and was honorably discharged, after which he became a writer, editor, and critic. Throughout his career, he purposely avoided political causes and refused to write about the Black experience. While he told his wife of his ethnicity, he hid it from his children and demanded his wife do the same. His children did not find out their heritage until 1990, when he was 70 years old and dying of prostate cancer.
3. Joshua Burdett's son is mixed race (half Black and half white) and presents as white. His mother, Frances Houston, repeatedly claims she's afraid he'll be treated differently "if people know he's Black", though he could easily "pass" as white (just as his father does) and never once experience the discrimination or disadvantages she fears.She was likely raised to believe in the "One drop rule", an extremely racist social policy that was even signed into law in some states in the USA in the early 1900s; Tennessee was the first to pass such legislation in 1910, and Virginia passed the "Racial Integrity Act of 1924". Some states also had laws called anti-miscegenation laws that made it illegal for people of different races to marry. For example, Montana's Anti-Miscegenation Act of 1909 made it illegal for white people to marry or have children with people of African, Chinese, Japanese, or Indian descent.In the early 20th century, there was an irrational fear of "invisible blackness" due to the increase of mixed-race children entering the population after slavery was outlawed. White supremacists believed that even "one drop" of African blood negatively impacted mixed-race children, lowering their intelligence and physical fitness, and even damaging their moral compass. Therefore, if you had any non-white or mixed-race person in your ancestry, you were considered "colored" (the term used at the time).Even those who self-identified as "Indian" (what is now called "Native American") were also classified as Black and subject to segregation laws that separated white people from non-whites.Thankfully, these laws were never adopted on the Federal level, and they are now obsolete in the United States.
4. The "Baby M" case referenced dealt with surrogacy law. There are two types of surrogacy: gestational: a fertilized egg is implanted into the carrier and no surrogate-DNA is present traditional: surrogate's own egg is fertilized and is the biological mother of the child In the case of Baby M, the surrogacy was traditional. Mary Beth Whitehead (surrogate) was impregnated with William Stern's sperm; child, a daughter (b. 27 Mar 1986) was to be raised by Stern and his wife. Instead, after handing over the child to the Sterns, Mary Beth Whitehead kidnapped the child and refused to return her, naming her Sara Elizabeth Whitehead. The Sterns sued Whitehead for custody, resulting in a protracted legal battle as she was the biological mother. The courts eventually awarded legal custody to the Sterns but Whitehead was granted visitation rights. Baby M was renamed Melissa Elizabeth Stern. Upon reaching legal age, Melissa Stern moved to legally terminate Whitehead's parental rights, then had the Sterns legally adopt her. Whitehead later married and had two more children. She wrote a book about her surrogate experience and the trial.
5. On the stand, 'Frances Houston' refers to golfer, Fuzzy Zoeller. At that year's US Masters (1997), former winner Zoeller, made racist comments about 21-year-old Tiger Woods, who had won the title, becoming the first non-white champion in its history.
6. Desyrel is a brand name for the serotonin antagonist and reuptake inhibitor (SARI) class antidepressant and sedative drug Trazodone. It is used to treat major depressive disorder, anxiety disorders, and insomnia.Parlodel is a brand name for the dopamine agonist drug Bromocriptine, which is used to treat hormonal issues caused by pituitary tumors, Parkinson's disease (PD), hyperprolactinaemia (a disorder that causes women who aren't pregnant to lactate), neuroleptic malignant syndrome, and type 2 diabetes.Halcion is a brand name for the benzodiazepine class drug Triazolam. It can be used to treat anxiety, although, because of its potency, it is mainly used to treat severe insomnia. Other, shorter acting and less potent benzodiazepines are preferred for the treatment of anxiety; the two most common being diazepam (Valium) and Alprazolam (Xanax).
7. This is the second appearance of Franchelle Stewart Dorn as defense attorney Ms. Joyner. Her previous appearance was in Season 7's Showtime (1997) as part of movie producer Eddie Newman's legal team in his murder trial.

Shadow

1. Kate Mara's first TV role.
2. David Marshall Grant (A.D.A. Charlie Harmon) also played corrupt A.D.A. Peter Bonham in Best Defense (2002).
3. This episode is based on a real life case presided over by New York Supreme Court Justice Leslie Crocker Snyder, who also acts as a legal advisor for this series, as well as Law & Order: Trial by Jury (2005). Justice Snyder was the presiding judge on a number of high profile murder, sexual assault, drug and mob cases. In 1989 Justice Snyder presided over the first case in the state of New York where a shadow counsel was used, the case is People v. Stewart as mentioned by ADA Ross. Lynn Stewart was a defense attorney, well known for her often effective defense of controversial figures, her clients included the leaders of some of New York's largest drug gangs, confessed murders and rapists; her most famous client was Sheik Omar Abdel Rahman, the mastermind behind the 1993 bombing of the World Trade Center. In 1989, Ms. Stewart was hired to represent Dominick Maldonado, a member of a Lower East Side drug gang, after he was arrested along with six other gang members on multiple drug trafficking charges. During his trial, Mr. Maldonado told the judge and prosecutors that he wanted to fire his lawyer, cooperate and testify against his boss. But he was afraid to discharge Ms. Stewart because the person who paid her fee was also the head of his gang, he feared that if he replaced her as his counsel, the head of his gang would find out he had become an informant, putting his life and the life of his family in danger. Mr. Maldonado, and another cooperating defendant Susan Chang, both testified that Ms. Stewart was also the attorney for the head of their gang, and that she had threatened both Maldonado and Chang to not cooperate or they would be killed. In order to protect Mr. Maldonado, and Ms. Chang, Justice Snyder arranged for several secret hearings in which she replaced Ms. Stewart with a new lawyer, called a ''shadow counsel.'' Mr. Maldonado and Ms. Chang agreed to cooperate and testify against both their boss and Ms. Stewart in exchange for a reduced sentence. The prosecution against Mr. Maldonado proceeded in a "sham" trial, while he cooperated in an investigation of Ms. Stewart. Ultimately news of the sham trial and shadow counsel became public knowledge, Ms. Chang died of cancer before her trial ended and the judge in Mr. Maldonado's sham trial did not appreciate being played, after Maldonado was convicted he sentenced him to 100 years in prison, Maldonado hung himself in his cell the next day. The sham trial came to light when prosecutors subpoenaed Ms. Stewart's business records to find out who was paying her, she filed a motion in the Appellate Division of the New York Supreme Court to quash it, which was denied. During the hearing the Appellate Division became aware of the shadow counsel, they determined that while its ethics were questionable, Justice Snyder hadn't done anything illegal by creating a shadow attorney for Maldonado and Chang. The DA's office charged Stewart with hindering prosecution and witness intimidation, but ultimately a state judge dismissed the charges against Stewart. The DA's office filed an appeal of the dismissal to the New York Court of Appeals, in People v. Stewart a three-judge majority ruled that the trial judge erred in dismissing the charges against Ms. Stewart before trial, and upheld the Supreme Court Appellate Division's ruling that Justice Snyder didn't violate the law, thereby setting the precedent for the legality of shadow counsel; although the Chief Judge of the Court of Appeals spoke out against the tactic as being unethical. The DA's office chose not to refile charges. Ms. Stewart wound up facing even more legal trouble later in her career when she defended Omar Abdel-Rahman after the WTC bombings. Stewart was convicted on charges of conspiracy and providing material support to terrorists in 2005 after she helped pass messages from Omar to members of the terrorist group he was a member of, she was initially sentenced to 28 months in prison and the felony conviction caused her to be disbarred. During her trial Stewart claimed she didn't know the person she was delivering messages to was a terrorist, nor did she know the messages related to terrorist activity. Evidence was later uncovered proving that she did in fact know these things, she was re-sentenced to 10 years in prison for perjury.
4. This episode appears to be based on the "shadow counsel" invocation.
5. This was an early role for Michael Kenneth Williams as the inmate Delmore Watson. He would become a celebrated, award winning, numerous Emmy nominated, talented actor with a massive career. He was most known for his performances in The Wire, Boardwalk Empire, Bessie, When They See Us and The Night Of. His large facial scar was the result of being attacked with razors in a bar on his 25th birthday. Sadly, he passed away in 2021 at the age of 54. He is greatly missed by his multitude of fans and costars.

Burned

1. Briscoe asks one of the people they are questioning if he is a friend of Bill W. This is a term that alcoholics use to identify one another and remain somewhat anonymous.
2. Attorney Weaver states that the defendant, Terry Lawlor, isn't "Howling at the moon". Sam Huntington plays Terry in this episode. He also plays Josh on Being Human (2011), a werewolf.

Ritual

1. First television appearance for actress Emmy Rossum.
2. Jamie Ross laments, "Judge O'Hara's a real piece of work; he'd award custody to Medea". This is a reference to the mythological character Medea, a priestess/sorceress featured in the epic "Argonautica" by Apollonius of Rhodes.In the story, which tells the tale of Jason and the Argonauts, Medea helps Jason find the golden fleece, then marries him and bears his children. After Jason leaves her for another woman (Creusa), Medea poisons Creusa and king Creon (Creusa's father), then murders her own children as part of her revenge against Jason.
3. Actress Abby Lewis/Mrs. Newman died a few weeks before this episode aired.
4. This episode appears to be based on the heightened concern over female genital mutilation.
5. Jacqueline Antaramian (Farrah Patel) also played the role of Donna Grimaldi in episode 10.8, Blood Money (1999).
6. The U.S. Customs inspector mentions someone coming from Cairo needing a visa because "Egypt isn't on our waiver program". He is referring to the Visa Waiver Program (VWP); Congress passed legislation in 1986 to create this program with the aim of facilitating tourism and short-term business visits to the United States and allowing the United States Department of State to focus resources on addressing higher risks associated with nationals of countries that do not have friendly relations with the U.S. or nations known to sponsor or participate in terrorism. It allows citizens of specific nations chosen by the Department of State, if the nation agrees to participate in the program, to travel to the United States for tourism, business, or while in transit for up to 90 days without having to obtain a visa (so long as they have a passport); this applies to all 50 states, the District of Columbia, and all U.S. territories including Puerto Rico, U.S. Virgin Islands, Guam, and the Northern Mariana Islands. Nationals of countries that aren't part of the waiver program must apply for a travel visa from the Department of State in order to travel to the United States; if the visa is approved, it will declare how long they are allowed to remain in the country. Following the September 11, 2001 terrorist attacks, the Bush Administration tightened entry requirements; starting in October of 2004, nationals of VWP countries would be required to present biometric passports in order to enter the U.S., which are also called e-passports and feature an embedded RFID microchip that contains biometric data to authenticate the passport. The VWP was amended by the Visa Waiver Program Improvement and Terrorist Travel Prevention Act of 2015, which added additional requirements and restrictions to visa waivers; this legislation was passed in response to the growing number of foreign nationals being recruited by terrorist organizations and traveling for training and indoctrination then returning to their home country to commit acts of terrorism, the November 2015 Paris terrorist attacks being an example. Under the Improved Visa Waiver Act, nationals of VWP countries must obtain a visa to enter the United States if they fall into one of the following categories: 1. have traveled to or been present in Iran, Iraq, Libya, North Korea, Somalia, Sudan, Syria, or Yemen on or after March 1, 2011; OR 2. have traveled to or been present in Cuba on or after January 12, 2021 (with limited exceptions for travel for diplomatic or military purposes); OR 3. Nationals of VWP countries who have dual-citizenship with Cuba, Iran, Iraq, North Korea, Sudan, or Syria.As of 2025, the following 43 nations are participants in the Visa Waiver Program: Andorra, Australia, Austria, Belgium, Brunei, Canada, Chile, Croatia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Israel, Italy, Japan, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Monaco, Netherlands, New Zealand, Norway, Poland, Portugal, Qatar, San Marino, Singapore, Slovakia, Slovenia, South Korea, Spain, Sweden, Switzerland, Taiwan, and the United Kingdom.
7. Suspecting Dr. Nasser of potentially being a terrorist because he was Egyptian, and had recently traveled to several European and Middle Eastern countries, isn't exactly unreasonable. For one, like Lt. Van Buren said his story of traveling 10,000 miles to make a house call doesn't make sense. Second, the perpetrators of several major terrorist attacks on the United States, and other countries, have matched that profile. Mahmud Abouhalima is an Egyptian citizen who participated in the 1993 bombing of the World Trade Center, in the years leading up to the bombing he had traveled to a few Middle Eastern nations including Saudi Arabia, and had previously been to Germany. Mohamed Atta is another infamous Egyptian terrorist, he was the leader of the terrorists that hijacked American Airlines Flight 11 on September 11, 2001 and was responsible for crashing the plane into the North Tower of the World Trade Center. He also had been to Germany, and in the years leading up to 9-11 traveled from Egypt to Afghanistan several times.

Under the Influence

1. This episode appears to be based on two separate cases/incidents:
   • The legal debate over filing first-degree murder charges for homicides caused by impaired driving.
   • The 1996 hit-and-run incident at Wake Forest University committed by Thomas R. Jones. He was sentenced to life in prison in 1997 for his role in the deaths of 2 students and the injury of 4 others while under the influence of Xanax, Percocet, Fioricet, and beer.
2. Claire Kincaid's death by collision with a drunk driver in the season 6 finale Aftershock (1996) is referred to in this episode.
3. Detective Tony Profaci says two hobos were debating the merits of thunderbird versus crack. Thunderbird is a term, often used by the homeless, for really cheap wine, usually homemade, also known as "toilet bowl wine." Thunderbird is also a brand name of low-quality, cheaply-priced wine.
4. Carrie Nation is referenced in passing. Caroline Amelia Nation was a radical anti-alcohol activist and prominent member of the Temperance movement, whose members sought to outlaw alcohol due to its effects on mental and physical health, work ethic, infant mortality, and its perceived involvement in political corruption, domestic violence, and poverty.Carrie was notorious for being armed with a hatchet that she used to destroy taverns and other establishments that served alcohol, either alone or by leading a raid to greatly increase the destruction. She was arrested more than 30 times and even banned from Kansas City at one point. Her actions led many bars to post signs stating, "All nations welcome... except Carrie".She died in 1911, about 9 years before the United States passed the 18th Amendment to the Constitution (Prohibition), banning the sale and manufacture of alcohol. The Amendment was proposed in 1917, ratified in 1919, and lasted until 1933 when it was repealed by the 21st Amendment. The prohibition of alcohol caused the rise of some of the nation's most notorious gangsters and criminal organizations such as Al Capone, and is a prime example of how in some instances laws aren't able to stop crime, and actually do the opposite and give criminals more wealth and power over law abiding citizens. Banning alcohol backfired so badly that it is the only time in the history of the United States that a Constitutional Amendment has been repealed.
5. Ross mentions that the Warsaw Convention protects international airlines from actions by state courts. The Warsaw Convention is an international treaty that governs the liability of airlines in international air travel, it was originally signed in Warsaw, Poland in 1929; it was amended at conventions in The Hague, Netherlands in 1955, and Guatemala City, Guatemala in 1971. It was replaced by the Montreal Convention of 1999. It establishes rules for passenger and baggage claims, including limits on airline liability for injuries, death, baggage loss or damage, and delays. The convention makes airlines liable for damages sustained in the event of passenger death or injury if the accident occurred on board the aircraft or during embarkation/disembarkation, and sets a two-year time limit for filing claims. It also covers liability for lost, damaged, or delayed baggage, with specific time frames for filing claims (7 days for damaged baggage, 14 days for delayed or lost baggage). The 1955 amendments adding airline liability for damages and injuries caused by intoxicated passengers who were over-served alcohol on flights. It also set a monetary limit for the amount damages an airline can be found liable for, that limit was updated by the Montreal Convention to adjust for inflation: $175,000 USD for personal injury claims, $20 USD per kilogram ($11 per pound) for lost or damaged cargo & checked luggage, and $476 for carry-on luggage. For person injury, or wrongful death, claims exceeding $175,000 the plaintiff must show, based on a preponderance of the evidence, that the airline was guilty of willful negligence, and that negligence was the precipitating cause of the incident that led to the injury or death. The Montreal Convention also removed the monetary limit for lost or damaged cargo, if the property lost or damaged was mobility or medical equipment (such as a wheelchair or respirator) that belonged to a passenger who is legally disabled.
6. The CSU mechanic mentions that cars often have a hidden VIN number to make it more difficult for thieves to alter or obscure the vehicle's identity. As mentioned the three commonly known locations of VIN numbers is the inside of the driver side dash, inside the driver's door jam, and the engine block. Either all or part of the VIN number is also often stamped on the frame, the firewall (the panel between the engine & passenger compartments), transmission, major body panels, wheel wells, under the hood, under the carpeting in the trunk, inside the spare tire well, and in the glovebox; the number & location of places the VIN is stamped varies by manufacturer. Since 2010, due to the widespread use of smartphones and digital tablets, many vehicle manufacturers have began stamping these aforementioned secondary locations with a special QR code instead of the VIN number. This is for various reasons, the main one is that QR codes can be very small compared to a stamped VIN number and are much harder to notice, this also allows them to be stamped on smaller parts; manufacturer QR codes are also encrypted and can only be read by special software not available to the consumer. The QR code also has the advantage of containing more than just the regular VIN number, but also contains an encrypted digital code unique to that vehicle, known only to the manufacturer and the FBI's National Crime Information Center (NCIC), forging or changing this code is substantially more difficult than forging a VIN. QR codes can also be encoded with additional useful information such as the vehicle's manufacture date, location of manufacture and batch number. Stamping QR codes on parts is also useful for internal manufacturing and tracking purposes, QR codes help manufacturers streamline production, manage inventory, and comply with regulations by providing quick access to serial numbers, manufacturing data, and other relevant information.QR codes are also commonly being used as identifying marks on other types of items that are prone to theft and criminal use such as firearms. Manufacturers like Glock, Heckler & Koch, Remington, Ruger, SIG Sauer, Smith & Wesson, and Winchester have began to stamp QR codes on upper & lower receivers, bolts, slides and barrels. The code contains the gun's make, model, serial number, caliber, barrel length, rifling type & size, date of manufacture and place of manufacture. As with automotive QR codes this is useful in making it more difficult for criminals to deface a firearm, as filing or etching down the serial number is pointless if the QR codes aren't all found and destroyed as well. But is also useful during the manufacturing process, and contains information that could be useful during warranty servicing, or servicing by a gunsmith.
7. Gary Feldman, the presiding judge over the case, plans to run for election to Adam Schiff's New York District Attorney seat.
8. Josh Stamberg (C.S.U. Mechanic) also played the part of Martin Stanley in Asterisk (2002) (episode 13.8).

Expert

1. Joanna Merlin has portrayed two different characters during the course of the series:
   • Episode 2.21 Silence (1992) - Carla Bowman.
   • Episode 3.19 Virus (1993) - Carla Bowman.
   • Episode 5.8 Virtue (1994) - Deirdre Powell.
   • Episode 6.18 Atonement (1996) - Deirdre Powell.
   • Episode 8.12 Expert (1998) - Deirdre Powell.
2. "Acevedo v. US" is mentioned a few times, which is a case that dealt with the warrantless search of an automobile. The case's actual name is California v. Acevedo, 500 U.S. 565 (1991), the case was argued before the Supreme Court of the United States on January 8, 1991 and decided on May 30, 1991. The case was an appeal of a ruling made by the California Court of Appeals, in a 6-3 decision the Supreme Court held that the police may search either an automobile, or any container in an automobile, without a search warrant provided that the search is supported by probable cause indicating the automobile contains contraband or evidence of a crime.The case involved defendant Charles Acevedo being observed by police leaving a building that was known to contain marijuana, he was observed carrying a brown paper bag the size of marijuana packages they had seen earlier. Acevedo placed the bag in the trunk of his car and drove off, police followed him and conducted a traffic stop, they opened the trunk and found the bag, which contained a felony amount of marijuana. Acevedo's lawyer filed a motion to suppress the bag on the grounds that the police didn't have a warrant, and argued that since the bag was in a closed container it did not fall under the plain sight exception for warrantless searches based on probable cause. The trial court denied the motion and Acevedo was convicted of felony possession with intent to sell, his attorney appealed the conviction to the California Court of Appeals, that court determined that the bag should have been suppressed on the grounds that a closed or locked container (like a trunk) grants a higher expectation of privacy and requires a search warrant, they set aside the verdict from the trial. The district attorney appealed the appellate court's ruling to both the California Supreme Court and the Supreme Court of the United States, based on the fact that the Supreme Court (in 1927) had previously held that police may search the entire contents of a vehicle if sufficient probable cause exists, also citing the United States Court of Appeals siding with that precedent in multiple instances. The U.S. Supreme Court granted the appeal based on its Fourth Amendment issues, the court upheld the precedent and ruled that if police have probable cause that contraband or evidence of a crime exists within an automobile, the police may search the entire vehicle and its contents, including any containers in the vehicle, without a warrant. The court further clarified that while the Fourth Amendment does provide a higher level of protection and expectation of privacy to closed or locked containers inside a person's home when it comes to warrantless searches, the "plain sight" rule, it does not provide the same level of protection to containers outside of a person's home or dwelling, and therefore police may search containers inside a vehicle without a warrant based on probable cause. The Supreme Court overruled the California Court of Appeals' decision to suppress the bag, and reinstated Acevedo's conviction.
3. Guest stars Vera Farmiga and Richard Hughes both appear in Martin Scorsese's film The Departed (2006).

Castoff

1. During the trial, Eddie Chandler lists The A-Team (1983) as one of the 'violent action shows' he grew up watching. "The A-Team" was notorious for having massive gunfire, multiple explosions, and numerous car and aircraft crashes, but nobody ever died. Despite being a #1 show in America during the 1980's, the show came under fire by parental and political groups alike for being too violent, and it was even frowned upon by their own network, NBC. Reportedly, Robert Keeshan blamed the show for America's drug problem. By vast comparison, in the Netherlands in the 1980s, the show was widely loved because 'there was no violence'.
2. This episode appears to be based on two separate cases/incidents:
   • The Andrew Cunanan case.
   • The debate of media portrayal of violence influencing criminal behavior.
3. Jack McCoy says the defendant "could blame it on moonbeams or Twinkies..."On November 27, 1978, San Francisco Supervisor Dan White carried out the premeditated assassinations of fellow San Francisco Supervisor Harvey Milk and San Francisco Mayor George Moscone but fled and turned himself in before committing the two other murders he had planned.During his trial, his defense team and his doctors claimed that White went from being upbeat and health-conscious to depressed and consuming almost nothing but sugary drinks and junk food. They claimed the diet caused or deepened his depression, leading to such an altered mental state that he didn't realize what he was doing was wrong.The jurors bought it, and White was convicted of voluntary manslaughter instead of murder, receiving only 7 years in prison. White served only 5 years of the 7 year sentence before being paroled.While Twinkies were not specifically blamed by White or his defense team, the media latched on to their mention and coined the term, "The Twinkie Defense". It is not actually an accepted legal defense, but it is a notorious one.
4. Adam Schiff tells Congressman Maxwell that, if the defense works, his political cause will "have [their] own Willie Horton".William Horton was a convicted felon who was given the privilege of a weekend furlough (he left prison for the weekend and was expected to return) despite already serving a life sentence without the possibility of parole for murder.On June 6, 1986, instead of returning to prison, Horton committed several more crimes, including binding, gagging, stabbing, and beating a man then repeatedly raping the man's fiancée. He capped off his crime spree by stealing their car and fleeing the area.Horton was eventually recaptured and re-sentenced to two consecutive life terms without the possibility of parole or furlough.Horton's case became a hot-button issue during the 1988 presidential campaign, and George H.W. Bush's campaign used it to argue against "weekend passes" also known as furloughs. Though not always specifically mentioned by name, Horton became the face of the argument against Bush's opponents, mostly Michael Dukakis, and he was featured in two notorious commercials, "Revolving Door" and "Weekend Passes", that helped secure Bush's win as they made him look "tough on crime".Horton remains incarcerated in Maryland.
5. Dennis Boutsikaris has played three different characters throughout the course of the series:
   • Episode 1.4 Kiss the Girls and Make Them Die (1990) - Richard 'Dick' Berkley.
   • Episode 3.4 The Corporate Veil (1992) - Richard 'Dick' Berkley.
   • Episode 7.3 Good Girl (1996) - Al Archer.
   • Episode 8.13 Castoff (1998) - Neil Pressman.
   • Episode 11.8 Thin Ice (2000) - Al Archer.
   • Episode 12.10 Prejudice (2001) - Al Archer.
   • Episode 14.17 Hands Free (2004) - Al Archer.
6. Very early role for J. D. Williams, one of the kids playing air basketball in the first scene. He would go on to have a huge career with major roles in "Oz" and "The Wire", to name a few.
7. Scott Whitehurst (Lester Metcal) previously played the role of Melman in Rage (1995) (episode 5.13).

Grief

1. This episode appears to be inspired by the 1995 case of "Kathy", a comatose woman who was raped and impregnated.
2. Since 2016, the number of states passing legislation to allow for the termination of a rapists parental rights has increased significantly. This is due to the passage of the Rape Survivor Child Custody Act (RSCCA), also known as H.R. 1257, by Congress in 2015. It created a federal law that incentivizes states to enact laws allowing for the termination of parental rights of rapists in cases where a child is conceived through rape. It does this by authorizing the Attorney General to award grants to states that have such laws in place. The state must demonstrate that the child was conceived through rape and use the "clear and convincing evidence" standard to determine whether the perpetrator committed rape.
3. The issue surrounding the legal parental rights of rapists has been a long and complex issue. As a general rule, it is very difficult for a rapist to win custody hearings or visitation rights, but, historically, the laws on the issue have varied by state. However, there have been cases where rapists were granted visitation or even partial custody rights. In general, courts are very hesitant to grant any rights to rapists, especially after the 1983 case of Lehr v. Robertson in the Supreme Court of the United States; in the case, the Supreme Court held that constitutionally-protected parental rights to a child do not spring solely from genetic parenthood, with Justice Stevens saying "they require relationships more enduring". This case set the precedent that a person being a biological parent doesn't automatically grant them any legal parental rights. Although, the 1993 cases of Hermesmann v. Seyer set a new precedent that complicated matters; it involved three different court rulings dealing with the issue of rape and child support. In the original case, a judge in the Kansas State District Court for the District of Douglas County ruled that a woman could compel the father of her child to pay child support, even if the child was conceived during a rape; this ruling was upheld by both the Kansas Court of Appeals and the Kansas Supreme Court. However, the laws of most states stipulate that a person who is paying child support has the right to sue for visitation rights or even partial custody; some rapists paying child support argued that law applied to them as well. In 2013, a Massachusetts case involved a man who pleaded guilty to statutory rape and was ordered to pay child support for the child conceived as a result. He filed later filed a petition in family court arguing that, if he had to pay child support, he should also have visitation rights. The family court judge granted the petition, and the 16-year old mother of the child is challenging this order in both the United States District Court for the District of Massachusetts and the Massachusetts Supreme Court on the grounds of it violating her civil rights by forcing her to be in contact with her rapist. As of this writing, the matter is still being litigated, and it has pending appeals with both the United States Court of Appeals for the First Circuit and the Massachusetts Supreme Court.
4. McCoy says they don't need the Russos to testify to make their prima facie case, as the sonogram proves when the fetus was conceived and it makes the crime of rape self-evident. McCoy is referring to a concept in common law known as "Res ipsa loquitur", a Latin phrase that translates to "the thing speaks for itself", and is used to refer to a situation where the court can infer negligence in the case of civil suits, or infer a crime was committed in criminal cases, from the very nature of the accident, injury or incident. In other words the evidence the prosecution has could only have been created by the commission of a crime. Typically in criminal cases, in order for charges to be filed against a defendant, the prosecution has to first establish their prima facie case, Latin for "at first sight" or "based on first impression", by having enough corroborating evidence to show that a crime was committed, and shows probable cause the defendant committed the crime. When it comes to sexual assault cases, typically the prosecution needs both the testimony of the victim detailing the sexual assault, and physical evidence that corroborates the details of the victim's testimony, to establish a prima facie case for sexual assault and bring charges against a defendant. But since a comatose woman by definition cannot consent to sexual activity of any kind, the conception of a fetus after she became comatose proves she was raped, its existence speaks for itself.Res ipsa loquitur is rarely used in criminal law, it's sometimes used in federal cases of unlawful possession of Title II NFA (National Firearms Act) firearms. Federal law says that certain unusually dangerous firearms like machine guns, short barreled rifles & shotguns, and firearm suppressors must be registered, and can only be possessed by the person(s) they are registered to; so someone found possessing such a firearm that either isn't registered, or is registered to someone else, their possession of that firearm automatically proves they committed a crime. The legal principle is most commonly used in civil cases, it allows a plaintiff to establish a defendant's negligence based on the circumstances surrounding the accident, rather than through direct evidence of negligent conduct. It essentially means that the accident itself is evidence of negligence, as it is the kind of accident that would not ordinarily occur without someone being negligent. The principle is often used in medical malpractice cases, if a person has surgery to remove their gallbladder, and they develop an infection after surgery due to a clamp being left inside their body, the mere presence of that clamp in the patient's body proves malpractice, since there is no legitimate reason for it to be there.
5. Stephen Singer has played six different characters over the course of the series:
   • Episode 2.9 Renunciation (1991) - Aaron Gerstein.
   • Episode 5.17 Act of God (1995) - David Pence.
   • Episode 8.14 Grief (1998) - Defense Attorney Baum.
   • Episode 11.3 Dissonance (2000) - Rafael Kessler.
   • Episode 15.7 Gov Love (2004) - Larry Levine.
   • Episode 19.16 Take-Out (2009) - Nathan Vick.

Faccia a Faccia

1. Vicky Grant (Kathrine Narducci), whose father was murdered by the mob, rants against the public fascination with gangsters: "These wiseguys, they are psychos and losers, and everybody loves them. And I don't get it." In real life, Narducci's own father was murdered by the mafia when she was 10 years old. Narducci also famously was in The Sopranos (1999) as Charmaine Bucco, the wife of Tony Soprano's best (non Mob) friend Artie Bucco. Her views on Tony Soprano (unsurprisingly) follow her character's sentiment in this episode as well.
2. "Doing a bullet" is slang for serving a one year jail sentence.
3. The "Son of Sam law" Ross refers to is a law that was created to make it illegal for a person to benefit financially from the publicity of their criminal act. The law was created after David Berkowitz (aka Son of Sam) was convicted; the case received world-wide media attention, and there was wide speculation that he would sell his story to a writer or filmmaker. While Berkowitz claimed he never had any interest in doing so, the government realized, for the first time, the inherent dangers that could come from a person believing they could become famous and rich from committing heinous crimes and legislation was quickly passed to outlaw it.
4. The title, "Faccia a faccia", is Italian for "Face to face".
5. This episode appears to be based on two separate cases:
   • The Sammy Gravano case.
   • The Vincent Gigante case.
6. An excerpt from Brendan Hall's book about Nick Lagrassa mentions "the day Frank Masucci got popped by the feds for murder". Frank Masucci was the head of the Masucci Crime Family, he served as the primary antagonist for season one of this series, and the Masuccis are also prominently featured in Law & Order: Criminal Intent (2001). Frank Masucci was first mentioned in the pilot episode Everybody's Favorite Bagman (1990), Detectives Greevey and Logan investigate several city council members, and a deputy police commissioner, who were accepting bribes from Masucci. Frank Masucci was the subject of another investigation in The Torrents of Greed: Part 1 (1991), Logan and Greevey discover the beating an attempted murder of a store owner was ordered by Masucci after he refused to sell Masucci's illegally imported and untaxed cigarettes, they also suspected him of having a union leader murdered. Masucci was arrested for attempted murder and murder, but was released on a technicality after a witness perjured himself. In part two of the episode, The Torrents of Greed: Part 2 (1991), EADA Stone convinced Masucci's brother-in-law to testify against him, Masucci had him killed, which in turn led to his own sister having Masucci killed as revenge for killing her husband. Detective Logan once again investigates the Masucci organization again after he transfers to the Major Case Squad in the season five episode Unchained (2005).
7. Ken Marks has played three different characters over the course of the series:
   • Episode 8.15 Faccia a Faccia (1998) - Agent Ruggiero.
   • Episode 11.7 Amends (2000) - Michael Sarno.
   • Episode 19.8 Chattel (2009) - Brian Klassen.

Divorce

1. This episode appears to be based on the divorce of Joseph P. Kennedy II and Sheila Brewster Rauch.
2. Despite the impression given in two of the user reviews of this episode, at no point in the story is there any evidence indicating that Sheila Atkins and Paul Redfield (the divorce attorneys played by Jill Clayburgh and Tony Roberts) were previously married to each other (or to anyone, for that matter). There is no basis for thinking or stating that they were - neither of them ever mentions it, nor do their clients, nor any of the detectives or prosecutors. The reviewers are mistaken - Atkins and Redfield are simply two ruthlessly competitive lawyers who enjoy besting each other.
3. Jill Clayburgh and Tony Roberts would appear opposite each other in a Broadway revival of "Barefoot In The Park" in 2006.
4. Haviland Morris (Molly Kilpatrick) previously appeared in Kiss the Girls and Make Them Die (1990) (episode 1.4), as Polly Norris.
5. Adam LeFevre has played seven different characters over the course of the series:
   • Episode 1.4 Kiss the Girls and Make Them Die (1990) - Bartender.
   • Episode 2.7 In Memory Of (1991) - Joseph Kelly.
   • Episode 3.6 Helpless (1992) - Dr. Helman.
   • Episode 6.19 Slave (1996) - Barry Clayton.
   • Episode 8.16 Divorce (1998) - David Harrigan.
   • Episode 10.10 Loco Parentis (2000) - Barry Clayton.
   • Episode 15.11 Fixed (2004) - Dr. Evodius Peters.
   • Episode 19.9 By Perjury (2009) - Peter Belanger.
6. Leonard, one of the mentally ill homeless suspects, thinks he's Pope Adrian VI. Adrian VI, born Adriaan Florensz Boeyens (March 2, 1459 - September 14, 1523), was the head of the Catholic Church from January 9, 1522 until his death 22 months later. Adrian had an influence on some of the most important and devastating events in human history. Adrian VI has the distinction of being the only Dutch Pope in the history of the church, and he was the last non-Italian to serve as Pope, until the Polish John Paul II 455 years later. Adrian VI is noted for being the personal tutor of Emperor Charles V, one of the most noted leaders of the Holy Roman Empire, with his influence being credited as one of the reasons Charles V expanded the empire's colonial territories; this influence led to the creation of colonies that would one day become some of the United States' largest cities. Charles V was also the Archduke of Austria, the King of Spain, and Lord of the Netherlands: he is also known for overseeing the establishment of some of the earliest North American colonies in the 1500's, making Charles V the first leader to have "an empire on which the sun never set", a phrase that would later come to refer to the British Empire as well. Adrian VI is probably best known for denouncing Martin Luther as a heretic and excommunicating him from the Catholic Church, which led to Luther founding the Lutheran Church, sparking centuries of conflict between the two religions that saw wide-scale religious persecution, people being burnt at the stake for heresy, and even large scale wars. One of the worst being the Thirty Years' War, lasting from 1618 - 1648, the war saw conflict throughout Central Europe; an estimated 4.5 million soldiers & 8 million civilians died from battle, famine, or disease. Some countries, like Germany, lost half their population; the Thirty Years' War was one of the most destructive conflicts in European history and one of the deadliest religious conflicts in human history.

Carrier

1. This episode appears to be based on the 1997 Nushawn Williams case. Also known as Shyteek Johnson, Williams is an American convicted sex offender who admitted in 1997 to having unprotected sex with numerous girls and women after having been told that he was HIV positive. New York state and local public health officials stated that Williams had sex with up to 47 women in Chautauqua County and 50-75 in New York City. Williams said in a news interview that his actual number of sexual partners was up to 300.
2. In the 25 years since this episode aired there has been huge advances in treating HIV and AIDS, when this episode aired about 50,000 people in the U.S. died each year from AIDS, in 2024 that number was down to approximately 18,000. In the mid 1990's the average life expectancy for AIDS patients was 18 months after diagnosis, as of 2024 for those taking antiretrovirals the life expectancy after AIDS diagnosis is over 40 years, and those who begin taking antivirals immediately after diagnosis of HIV exposure have a normal life expectancy, with over 95% never developing AIDS. In the 1990's the main treatment for AIDS was zidovudine, an antiretroviral commonly called AZT belonging to a class of drugs called nucleoside reverse transcriptase inhibitors (NRTI), it is still used in AIDS treatment, although no longer by itself. Research in the mid to late 1990's showed that the key to treating AIDS was to use a cocktail of multiple types of antiviral drugs, as of 2024 the most common cocktail consists of nucleoside reverse transcriptase inhibitors and integrase strand transfer inhibitors. A common example is the drug Biktarvy, a tablet containing three antiretrovirals: bictegravir, a human immunodeficiency virus type 1 (HIV-1) integrase strand transfer inhibitor; and emtricitabine & tenofovir alafenamide, both HIV-1 nucleoside analog reverse transcriptase inhibitors. AZT is still used in combination with other NRTI's in the form of Trizivir, it contains three reverse transcriptase inhibitors: abacavir sulfate (ABC), lamivudine (3TC) and zidovudine (AZT). Studies of Biktarvy, Trizivir and other similar drugs have proven that HIV positive patients on drugs such as these, who have no detectable viral load, are not contagious and cannot spread the virus via sexual contact. Since 2010 drugs have been developed for use as a PrEP (pre-exposure prophylaxis), which are taken by those at high risk for HIV exposure, or taken after possible exposure. Two common examples are Truvada (emtricitabine/tenofovir disoproxil fumarate) and Descovy (emtricitabine/tenofovir alafenamide), when taken for 28 days after potential exposure they have been shown to be 99% effective at preventing HIV infection. In 2025 a new long action PrEP drug called lenacapavir (Sunlenca) was given FDA approval to give constant protection against HIV infection for healthcare workers, those with a HIV positive a partner, and others who are at high risk of exposure such as sex workers, it is given in the form of a subcutaneous injection once every six months.
3. Heather Burns (who guest starred in this episode) co-starred in Miss Congeniality (2000) with Benjamin Bratt (Detective Rey Curtis).
4. Pneumocystis pneumonia (PCP) is one of the most common complications of AIDS, and one of the most common causes of death for AIDS patients, although in the decades since this episode aired there has been substantial progress in treating it, and AIDS overall. PCP pneumonia is an opportunistic infection caused by the yeast-like fungus Pneumocystis jirovecii, this fungus is commonly found in dust particulates in the air, and therefore is commonly found in people's lungs. It normally doesn't cause disease in those who are healthy, since the immune system is able to easily target and destroy the fungal spores, however in people with weak immune systems like AIDS patients, and patients taking strong immunosuppressants for cancer, organ transplantation, or severe autoimmune diseases like autoimmune vasculitis, systemic lupus, multiple sclerosis, scleroderma, or systemic rheumatoid arthritis, the immune system is unable to produce enough white blood cells to kill the fungus. If the fungal spores aren't killed, they embed themselves in the tissue of the lungs and begin to multiply and interfere with normal lung function, causing fluid buildup, anoxia (low tissue oxygen), hypoxia (low oxygen levels in the brain), and eventually death from asphyxia.
5. Leslie Denniston has appeared as five different characters over the course of the series:
   • Episode 4.14 Censure (1994) - Sara Felder.
   • Episode 5.16 Wannabe (1995) - Mrs. Prescott.
   • Episode 8.17 Carrier (1998) - Lenore Kiley.
   • Episode 12.3 For Love or Money (2001) - Elizabeth Dumas.
   • Episode 16.14 Magnet (2006) - Ellen Loomis.

Stalker

1. The concierge tells Briscoe a resident is genuinely from "Toad Suck" Arkansas. There is indeed such a place in the state, an unincorporated, 8-block community. (There is also a national park in Texas with the same name).
2. This episode appears to be based on two separate cases/incidents:
   • The 1989 Cindy James case. James was a Canadian nurse who disappeared from Richmond, British Columbia, on May 25, 1989. She was found deceased approximately two weeks later in the yard of an abandoned house, hogtied and with a nylon stocking wrapped around her throat. An autopsy indicated that she had died of an overdose of morphine, diazepam, and flurazepam. James's death was notable as she had made numerous reports to authorities dating back to 1982, alleging that she had been a victim of various acts of stalking, harassment, vandalism, home invasions, and physical attacks perpetrated by an unknown assailant.
   • The 1988 Richard Farley case. On February 16, 1988, a mass shooting occurred at the headquarters of ESL Incorporated in Sunnyvale, California. 39-year-old Richard Farley shot and killed seven people and wounded four others. A former employee of the company, he stalked his co-worker Laura Black for four years beginning in 1984. Farley was convicted of seven counts of first-degree murder and is currently on death row at San Quentin State Prison.
3. At the time this episode takes place, 1998, there were no specific laws that criminalized the act of stalking. This episode aired about a year prior to New York passing its first anti-stalking law: The Clinic Access and Anti-Stalking Act of 1999; this law made stalking a specific offense and allowed for the prosecution of individuals engaging in stalking behavior. The law was amended in 2014 to add provisions for electronic stalking and to add more severe penalties for repeat offenders of stalking. It amended New York State's stalking statutes to allow law enforcement to pursue criminal charges against those who use GPS or other electronic tracking devices to stalk their victims, and it allows law enforcement to prosecute perpetrators for the crime of stalking in the fourth degree, without requiring the victim to press charges or to file an order of protection, in the instances of electronic stalking. This amendment also increases the penalties for someone convicted of domestic violence or who has an order of protection against them for domestic violence, who engages in the act of criminal stalking. A related law passed in 2019, called the Extreme Risk Protection Order (ERPO) law, has a red-flag provision for those with registered firearms that allows law enforcement, family members, and certain school officials to petition a court to temporarily restrict a person's access to firearms if they pose a significant risk of harm to themselves or others. The ERPO's red-flag provision received a very controversial amendment in 2022 that allows firearms to be confiscated by law enforcement who are called to perform wellness checks based solely on complaints of harassment, stalking, or threats, allowing law enforcement to confiscate legally registered firearms even when they have no warrant, court order, or physical evidence of criminal activity. This recent amendment is being challenged in court as a violation of the Second, Fifth, and Fourteenth Amendments, as it allows law enforcement to confiscate and deprive people of constitutionally protected property without due process of law.
4. After Russell Lowery is convicted of attempted murder in the second degree and murder in the second degree, McCoy says they will be asking for a sentence of life without the possibility of parole. Normally, only murder in the first degree and aggravated murder carry sentences of life without parole, murder two usually carries a maximum sentence of life in prison with the possibility of parole after 25 years, and attempted murder two carries a minimum sentence of 5 years in prison, and a maximum sentence of 25 years; typically a conviction of attempted murder two and murder two, would carry a sentence of 30-50 years to life in prison. However Lowery has previously been convicted of multiple felonies, including violent felonies. Under New York's habitual felon sentencing guidelines (similar to some state's "three strikes" laws), someone who has previously been convicted of at least two violent felonies, and is subsequently convicted of voluntary manslaughter, attempted murder, or murder, can be sentenced to life without the possibility of parole.
5. Robert Joy (Louis Dutton) previously played the role of Leo Barnett in Pride (1995) (Episode 5.23).
6. Daniel Oreskes has played six different characters over the course of the series:
   • Episode 5.23 Pride (1995) - Durban Campaign Manager.
   • Episode 7.2 I.D. (1996) - Jack Maslin.
   • Episode 8.18 Stalker (1998) - Mr. Wilson.
   • Episode 11.24 Deep Vote (2001) - Jeff Waites.
   • Episode 13.20 Kid Pro Quo (2003) - Merrill Rush.
   • Episode 17.19 Fallout (2007) - Andrei Karpovich.

Disappeared

1. McCoy mentions that he must attend a bail hearing for a Charlie Harmon so Jamie will have to handle the sentencing phase of the O'Dell on her own. The character Charlie Harmon had appeared in Season 8, Episodes Harvest (1997) and Shadow (1997). Harmon was a friend of Jamie and a low-level ADA. He was convicted of murder in Episode 8.
2. This episode appears to be based on the Ted Kaczynski (a.k.a. "The Unabomber") case. Kaczynski was an American domestic terrorist, anarchist, and mathematical prodigy who, between 1978 and 1995, engaged in a nationwide bombing campaign against people involved with modern technology. He planted or mailed numerous homemade bombs, ultimately killing a total of three people and injuring 23 others. He is also known for his wide-ranging social critiques, which opposed industrialization and modern technology while advancing a nature-centered form of anarchism. He became well-known for sending bombs with false return addresses that belonged to real people, and he was the target of one of the Federal Bureau of Investigation's costliest investigations. Before Kaczynski's identity was known, the FBI used the title "UNABOM" (UNiversity & Airline BOMber) to refer to his case, which resulted in the media calling him the Unabomber. The FBI (as well as Attorney General Janet Reno) pushed for the publication of Kaczynski's "manifesto", which led his sister-in-law and then his brother to recognize Kaczynski's style of writing and beliefs, and they tipped off the FBI. Kaczynski tried unsuccessfully to dismiss his court-appointed lawyers because they wanted to plead insanity in order to avoid the death penalty, as Kaczynski did not believe he was insane. When it became clear that his pending trial would entail national television exposure for Kaczynski, the court entered a plea agreement, under which he pleaded guilty and was sentenced to life in prison with no possibility of parole. Although Kaczynski was arrested two years after the episode aired, he interestingly shares some similarities with the defendant: both were disgruntled scientific geniuses, had thick beards, lived simple lifestyles, and eventually targeted scientists in bombings.A striking resemblance exists between the defendant and Kaczynski. Both were Ivy League-educated geniuses with very high IQs, though both suffered from long-term mental illness. Both were overzealous crusaders against progress. Both were ultimately apprehended by their own brothers turning them in upon recognizing their writings sent to the newspapers--letters in Odell's case, while the Unabomber submitted a manifesto.
3. Actor Seth Barrish plays Michael O'Dell's first attorney Ralph Staggs, who is promptly fired and replaced by Danielle Melnick. Barish plays a mentally ill man, Harvey Bower, in Collision (2000). His character's attorney in that episode is also Danielle Melnick.
4. In the beginning of this episode, the detectives discover a video of Alfred Hitchcock's Strangers on a Train (1951) in the missing woman's shopping bag. A video of Strangers on a Train (1951) also features in Bedfellows (2006) where it is an important plot point.
5. Michael Medeiros has portrayed six different characters over the course of the series:
   • Episode 4.20 Nurture (1994) - Detective Harding.
   • Episode 7.5 Corruption (1996) - Internal Affairs Detective Reynolds.
   • Episode 8.19 Disappeared (1998) - Matthew O'Dell.
   • Episode 12.3 For Love or Money (2001) - Vince Renalfi.
   • Episode 14.8 Embedded (2003) - Defense Attorney Stewart Griffin.
   • Episode 18.16 Strike (2008) - Mike Dolci.

Burden

1. Leslie Hendrix was pregnant while filming this episode.
2. This episode appears to be based on several different cases/incidents: -The 1981-1997 Michael Swango case. Swango is an American serial killer and licensed Ohio physician who is estimated to have been involved in as many as sixty fatal poisonings of patients and colleagues, although he admitted to only causing four deaths. He was sentenced in 2000 to three consecutive life terms without the possibility of parole and is serving his sentence at ADX Florence at his own request.
   • The 1970-1982 Genene Jones case. Jones is an American serial killer, responsible for the deaths of up to sixty infants and children in her care as a licensed vocational nurse during the 1970s and 1980s. In 1984, Jones was convicted of murder and injury to a child. She had used injections of digoxin, heparin, and later succinylcholine to induce medical crises in her patients, causing numerous deaths. The exact number of victims remains unknown; hospital officials allegedly misplaced and then destroyed records of Jones' activities to prevent further litigation after Jones' first conviction.
   • The 1993-1994 Robert Latimer case. Latimer is a Canadian canola and wheat farmer who was convicted of second-degree murder in the death of his daughter Tracy Lynn Latimer (born November 23, 1980 - October 24, 1993). This case caused a national controversy concerning the definition and ethics of euthanasia as well as the rights of people with disabilities, and it resulted in two Supreme Court decisions, R. v. Latimer (1997), on section 10 of the Canadian Charter of Rights and Freedoms, and later R. v. Latimer (2001), concerning cruel and unusual punishments with reference to section 12 of the Charter. Latimer was released on day parole in March 2008 and was granted full parole in December 2010.
   • The Dr. Jack Kevorkian case. Dr. Kevorkian became famous in the late 1980s and early 1990s as a supporter of assisted suicide. He became most noted for publicly championing a terminal patient's right to die via euthanasia; he claims to have assisted at least 130 patients to that end. He famously said that "dying is not a crime." Between 1999 and 2007, Kevorkian served eight years of a 10-to-25-year prison sentence for second-degree murder. His trial was a lengthy one because of several acquittals and a mistrial. He was released, on June 1, 2007, on parole due to good behavior. He died on June 3, 2011.
   • The controversial scandals of increasing risk to patient safety from trends of medical malpractice in medical centers and clinics.
   • The legal and ethical debates of a person's right to die based on the burden of disease outweighing disability rights.
3. Heather Matarazzo also appeared in Sweetie (2008).
4. Gerry Bamman has played four different roles over the course of the series:
   • Episode 1.22 The Blue Wall (1991) - Internal Affairs Lieutenant Kennedy.
   • Episode 5.11 Guardian (1995) - Dean Pollard.
   • Episode 7.2 I.D. (1996) - Stan Gillum.
   • Episode 8.20 Burden (1998) - Stan Gillum.
   • Episode 10.13 Panic (2000) - Stan Gillum.
   • Episode 11.17 Ego (2001) - Stan Gillum.
   • Episode 14.12 Gaijin (2004) - Judge Thomas Everton.
   • Episode 16.11 Bible Story (2005) - Judge Thomas Everton.
5. Maryann Plunkett has portrayed three different characters over the course of the series:
   • Episode 6.21 Pro Se (1996) - Joanne Ellis.
   • Episode 8.20 Burden (1998) - Lois Sutter.
   • Episode 12.14 Missing (2002) - Mrs. Weldon.
6. Danny Burstein has played five different roles over the course of the series:
   • Episode 5.19 Cruel and Unusual (1995) - Joe Garvey.
   • Episode 8.20 Burden (1998) - Howe.
   • Episode 11.12 Teenage Wasteland (2001)- A.D.A. Lester Rosenfeld.
   • Episode 12.23 Oxymoron (2002) - Peter.
   • Episode 19.11 Lucky Stiff (2009) - Surrogate Murray.
   • Episode 20.12 Blackmail (2010) - Judge Sam Murray.
7. Most of the non recurring charges assist to be named after NHL player, Lindros, Semenko, McSorely, Goring, Nicholls, etc

Bad Girl

1. This episode is based on the following case: The 1998 Karla Faye Tucker case. Tucker was a Texas woman executed in 1998, despite leniency pleas on her behalf based on her conversion to Christianity and her becoming a model inmate. Karla, along with her accomplice, were convicted of murdering Jerry Lynn Dean and Deborah Thornton.
2. The episode's murder suspect is played by Isabel Gillies, who later had a recurring role on Law & Order: Special Victims Unit (1999) as Elliot Stabler's wife Kathy.
3. Judge Gary Feldman announces he is running for District Attorney for New York County in the next election. New York is one of the states that has a "resign to run law", which requires sitting judges to resign from the bench if they are going to run for a political office like mayor, district attorney, attorney general, or governor. This is to ensure that a judge doesn't neglect their duties while campaigning, and in the event they are elected it prevents conflicts of interest. For example a judge is required to decide cases without bias or prejudice, they can't show any favoritism to the prosecution or defense, and they are to consider the defendant innocent until proven guilty; whereas the DA's job is to prosecute a defendant and attempt to prove their guilt, which requires as assumption of guilt, if the DA was also a judge it would be impossible to retain his impartiality. There is no requirement in the federal system for judges to resign prior to running for federal office, including the office of President, however they are required to resign from the bench if they are elected. Federal judges in the United States District Court, United States Court of Appeals, and the Supreme Court of the United States are appointed for life, unless they resign or are impeached by the Senate, these positions are intended to be independent and impartial, so while there is no strict requirement for federal judges to step down first, most judges consider it ethically important to resign from their position before seeking political office, since running for high offices like Attorney General or President could compromise a judge's impartiality; for example Justice Charles Hughes resigned from the Supreme Court to run for president in 1916, he felt running for office would make it difficult to remain impartial as a judge.As an interesting side note when it comes to judges and the office of president, William Howard Taft holds four unique distinctions in that regards: he is the only person who has served as a federal judge and as president, the only person who has been an appellate court judge and president, and the only person to serve on the Supreme Court & serve as chief justice, and be president; William Taft served as a Judge for the United States Court of Appeals for the Sixth Circuit from March 17, 1892 - March 15, 1900, he was the 27th President of the United States from March 4, 1909 - March 4, 1913, and he was appointed to the Supreme Court as the 10th Chief Justice of the United States from July 11, 1921 - February 3, 1930.
4. Julian Gamble has played four different roles in five appearances over the course of the series:
   • Episode 6.2 Rebels (1995) - Councilman Jack Rabe.
   • Episode 7.2 I.D. (1996) - Judge Slattery.
   • Episode 8.21 Bad Girl (1998) - Judge P. Slattery.
   • Episode 9.18 Juvenile (1999) - Gerald Fox.
   • Episode 14.14 City Hall (2004) - Ladder Company 66, Chief.
5. In eight guest appearances, Mark Lotito has played six different roles over the course of the series:
   • Episode 3.20 Securitate (1993) - Bailey.
   • Episode 4.4 Profile (1993) - Policeman #1.
   • Episode 5.1 Second Opinion (1994) - Paramedic.
   • Episode 6.18 Atonement (1996) - Nance.
   • Episode 8.21 Bad Girl (1998) - Detective Mallory.
   • Episode 8.22 Damaged (1998) - Detective Mallory.
   • Episode 8.24 Monster (1998) - Detective Mallory.
   • Episode 13.7 Open Season (2002) - Bartender.
6. There's debate about whether Monica Johnson saw Detective Flynn's badge, McCoy says they can prove murder, but which degree of murder Johnson is guilty of might have to be decided by the jury. In order for a defendant to be charged with intentionally killing a police officer under either murder in the first degree, or aggravated murder, the prosecution must prove that the defendant had reasonable cause to believe the victim was a police officer. So the fact that the victim is a police officer does not automatically elevate the charge to first degree murder or aggravated murder, the defendant has to have known the victim was a police officer, if the defense can prove the defendant didn't know the victim was a police officer then the charge is reduced to murder in the second degree. If there isn't evidence to clearly show whether or not the defendant knew the victim was a police officer, then that will be a matter left to the jury to decide, so first the jury must decide if the defendant is guilty of murder, then they must decide if the defendant knew the victim was a police officer. So when it comes time to render a verdict, the jury must decide one of the following: the defendant is guilty of murder in the first degree; or the defendant is not guilty of murder in the first degree, but guilty of murder in the second degree; or the defendant is not guilty of all charges.
7. After being found guilty of murder in the first degree and sentenced to death, Monica Johnson says that she is waving her right to an automatic appeal, and all appeals after that. The landmark case in the Supreme Court of the United States, Gregg v. Georgia (1976), set standards for death penalty cases to ensure that the death penalty is applied to all persons equally, and to ensure there isn't mitigating circumstances that might warrant a lesser sentence. In Gregg v. Georgia, the Supreme Court directed that whenever someone is sentenced to death in a state court their case is to be automatically reviewed by that state's highest court, for Georgia that is the Georgia Supreme Court, in New York the highest court is the New York Court of Appeals. The state's supreme court reviews the case to ensure the proceedings were fair and the law was applied correctly, if the state's highest court affirms the death sentence the defendant can petition the Supreme Court of the United States for a writ of certiorari asking them to review the case, although it is rare for the Supreme Court to accept these petitions. This is usually the end of the appeals process for state death sentences, although if the defendant's lawyer feels there is evidence to show there may have been some kind of judicial or prosecutorial misconduct during the trial, or if new evidence is uncovered that indicates the death penalty is inappropriate, then the defense can file for a writ of habeas corpus with the appropriate federal district court, in the case of New York City that would be the United States District Court for the Eastern District of New York. If the district court denies the habeas corpus writ, one can be filed with the appropriate federal appellate division, for NYC that would be the United States Court of Appeals for the Second Circuit; if the Court of Appeals denies the writ one final appeal can be made to the Supreme Court of the United States. A death sentence handed down in federal district court is automatically reviewed by the court of appeals, the remaining avenues of appeal are the same as a state death sentence; so a death sentence given in the United States District Court for the Eastern District of New York, would be automatically reviewed by the United States Court of Appeals for the Second Circuit.So altogether a death penalty case has a potential total of five different avenues of appeal, this is why it isn't uncommon for a defendant to be on death row for over a decade before being executed, and it's why it almost always costs the state twice the amount of money to execute someone, than it costs to imprison them for life, due to the court fees associated with the appeals process.
8. The voice of the woman who is in Al Johnson's bed sounds like actress Marie Michael. Her credits include Goodfellas and True Love.
9. Neal Jones (Mr. Flynn) and Jerry Orbach (Lenny Briscoe) previously acted together in Dirty Dancing. Neal Jones as Billy, and Jerry Orbach as Dr. Jake Houseman.
10. In 6 guest appearances, Jason Kolotouros has portrayed three different characters throughout the series: Episode 8.21 Bad Girl (1998) - Tilden. Episode 11.2 Turnstile Justice (2000) - Dr. Sanders.
    • Episode 13.1 American Jihad (2002) - Derek Greer.
    • Episode 13.14 Star Crossed (2003) - Derek Greer.
    • Episode 14.7 Floater (2003) - Derek Greer.
    • Episode 17.15 Melting Pot (2007) - Derek Greer.

Damaged

1. This episode appears to be based on two separate cases:
   • The 1989 Glen Ridge High School rape case. In 1989, an intellectually disabled 17-year-old girl was raped with a broomstick and a baseball bat by members of the Glen Ridge High School football team in Glen Ridge, New Jersey. This event attracted nationwide attention, mainly due to the perception that the assailants had been given special treatment by the school and local authorities due to their status as local football stars.
   • The 1991 Thomas Jefferson High School shooting in Brooklyn. In 1991, Darryl Sharpe, a ninth-grade student who was an innocent bystander, was shot to death in the school. Another youth was trying to help his brother in a fistfight, drew a gun, and opened fire in the crowded hallway. The three shots killed the 16-year-old student and critically wounded a teacher, Robert Anderson, who was approaching to intervene. At the time, education officials in New York called it "one of the school system's worst crimes" and noted that besides an accidental shooting in 1989, it was the first killing of a student in a school in more than a decade. The 14-year-old shooter, Jason Bentley, was sentenced to three to nine years in prison. Bentley was on parole for this homicide on June 22, 1997, when Luis Cabral Corcino was murdered in a robbery. Bentley was convicted of murder and was sentenced to 35 years to life.
   • The Patrick Daly case and the related 1998 People v. Russell case.
2. Detective Lennie Briscoe's daughter is killed at the end of the episode.
3. The ballistics lab technician says the shooter using the 9-mm was firing in a manner consistent with a fusillade. Fusillade is a technical term that describes a military unit firing a salvo of shots at once on command. As it applies to this case, fusillade can also mean a volley of shots fired in order to keep an enemy(s) pinned down and forced to stay behind cover--commonly known as suppressing fire or covering fire. Suppressive fire isn't intended to actually kill or harm an opponent: It is intended to make it more difficult for an opponent to shoot accurately at one or one's ally, especially while moving to a different position.
4. Judge William Wright sets aside the verdict in this episode just as he would do in the later episode entitled Gunshow (1999).
5. Rey Curtis' request to transfer out of the 27th Precinct is met with resistance by Lt. Van Buren. However, Curtis ends up taking an early retirement due to his wife's MS diagnosis at the end of the following season in "Refuge: Part 2".
6. Robert Clohessy has played four different roles over the course of the series:
   • Episode 8.22 Damaged (1998) - Defense Attorney Painte.
   • Episode 10.10 Loco Parentis (2000) - Robert Telford.
   • Episode 15.20 Tombstone (2005) - Kenny Peluso.
   • Episode 19.19 All New (2009) - Fire Chief.
7. A judge cannot reverse a verdict simply because they personally disagree with the jury's conclusion. They must identify a clear, objective legal error or a total lack of evidentiary support. Parties often must have moved for a "directed verdict" or "judgment as a matter of law" before the jury reached its decision to preserve the right to ask the judge to set aside that verdict later. This means the judge is often deciding on a motion that was already flagged during the trial, rather than acting on an impulse immediately after the verdict is read.
8. Knowing the danger Briscoe's daughter would be in they would have placed her in protective custody until the next trial
9. Mark Lotito has played six different roles over the course of the series:
   • Episode 3.20 Securitate (1993) - Bailey.
   • Episode 4.4 Profile (1993) - Policeman #1.
   • Episode 5.1 Second Opinion (1994) - Paramedic.
   • Episode 6.18 Atonement (1996) - Nance.
   • Episode 8.21 Bad Girl (1998) - Detective Mallory.
   • Episode 8.22 Damaged (1998) - Detective Mallory.
   • Episode 8.24 Monster (1998) - Detective Mallory.
   • Episode 13.7 Open Season (2002) - Bartender.
10. Kate Skinner who plays defense attorney Wilderman in this episode was married in real life to Ron McLarty who plays Judge William Wright in this episode until his death from dementia in 2020.
11. Real life incidents similar to the events of this episode, a minor having unrestricted access to a lawfully owned and registered firearm, is partly what led to New York passing the Secure Ammunition and Firearms Enforcement (SAFE) Act of 2013. It requires guns to be stored unloaded, and in a locked safe when not in use if there are minors under the age of 18 living in the home, or if the residence is shared by a person who is legally prohibited from possessing a firearm; it also includes harsh penalties if a gun is not properly stored and unlawfully used by a minor, or stolen and used in a crime. The majority of gun owners agreed with this provision of the act, as it is sensible for preventing the unauthorized use of a gun by children and criminals. However the SAFE Act has other provisions that are controversial, with many being challenged in court, and a few even being declared unconstitutional by the courts. The SAFE Act redefined "assault weapons" to include semi-automatic rifles, pistols, and shotguns with just one listed military-style feature (like a folding stock or threaded barrel), whereas previously, they needed two or more. It also created a requirement for firearms classified as assault weapons to be registered, and created a permit requirement for purchasing semi-automatic rifles, with a clause that requires a person to have a "compelling reason" to own such a weapon. It banned the civilian possession of magazines with a capacity over 10 rounds. It was also amended to require assault weapons to have fixed magazines. It also created the requirement for background checks to be done for all ammunition purchases, and requires a person to have a New York handgun permit to purchase handgun ammo, ammunition can only be purchased from a dealer with a Federal Firearms License (FFL), and online ammo purchases must be shipped to a FFL. The SAFE Act also requires background checks be done for all private firearm sales.Many of these provisions have faced legal challenges for infringing on constitutional rights of law abiding citizens, and criticism for doing little to prevent crime. The restrictions on "assault weapons" mainly just regulates cosmetic features that do very little to change the actual function of a firearm, and many of the restrictions it places on firearms can easily be overcome by criminals. The magazine restrictions are easily circumvented by criminals due to advances in 3D printing technology. New York's requirement for handgun carry permits, and semi-automatic rifle permits, to only be issued to those "with a compelling need", also known as a "may issue" policy, was repealed by the courts in 2022. In the case of New York Rifle & Pistol Association v. Bruen (2022), the Supreme Court of the United States held in a 6-3 ruling that "may issue" policies violated the Second Amendment's right to bear arms, the Supreme Court ruled that it is unconstitutional to not issue a permit to a person who meets the legal requirements for owning a handgun, or rifle in the case of semi-auto rifle permits. The court also held that there is no large gain to the rights of society by denying carry permits for handguns, as statistics show that conceal carry permit holders are overwhelmingly law abiding citizens, and violent crimes committed by carry permit holders is extremely rare. This ruling outlawed "may issue" policies nationwide, all states are now required to issue carry permits to those who qualify to possess a firearm under federal and state law.
12. When the dad hands the gun over the counter to detectives Briscoe and Curtis, they both handle the entire gun including the grip without gloves. Then they tell the young girl in interrogation her fingerprints will be all over it. Not anymore. It will be theirs.

Tabloid

1. This episode was co-written by actor Alec Baldwin, who based the episode in part on his own experiences with tabloid journalism.
2. The victim, whose face is never seen, is named Maggie Abbott. That was also the name of Tom Hanks' dead wife, Maggie Abbott (Baldwin) in Sleepless in Seattle (1993). That role was played by actress Carey Lowell, who plays Jamie Ross, the assistant to ADA Jack McCoy.
3. Discussing the ethics of journalism, Adam Schiff said 'The public still remembers a mangled car in a Paris tunnel.' This is a reference to paparazzi harassment initially believed to have been the cause of the death of Diana, the Princess of Wales, in a car crash in a Paris road tunnel.
4. Actor Peter McRobbie has portrayed five different characters over the course of the series:
   • Episode 1.21 Sonata for Solo Organ (1991) - Manager.
   • Episode 3.9 Point of View (1992) - John Ennis.
   • Episode 5.11 Guardian (1995) - Herbert Fowler.
   • Episode 8.23 Tabloid (1998) - Dr. Thomas Neustadt.
   • Episode 11.9 Hubris (2001) onward - Judge Walter Bradley.
5. This episode appears to be based on the deaths of Diana Spencer the Princess of Wales and Dodi Fayed caused by Henri Paul. Both were killed on August 31, 1997 as a result of injuries sustained in a car crash in the Pont de l'Alma road tunnel in Paris, France. Her companion, Dodi Fayed, and the driver of the Mercedes S280, Henri Paul, were pronounced dead at the scene. A fourth passenger in the car, bodyguard Trevor Rees-Jones, was seriously injured but survived. Her death was initially blamed on the paparazzi: several cars from tabloid media outlets were chasing Diana's car through the tunnel while trying to take photos of her. Eyewitness reports claimed that one of the paparazzi's cars sideswiped Diana's car, causing the crash. Although the media blamed the behavior on the paparazzi who followed the car, a French judicial investigation in 1999 found that the crash was caused by Henri Paul, the deputy head of security at the Hotel Ritz, who lost control of the Mercedes at high speed while he was intoxicated and under the effects of prescription drugs. Paul had been drinking earlier, and the anti-psychotic and anti-anxiety medications he was taking intensified the intoxicating effects of the alcohol he drank. He had goaded the paparazzi waiting outside the hotel earlier.
6. Ironically, Alec Baldwin later played a journalist in the Law & Order: Special Victims Unit (1999) episode Criminal Stories (2014).
7. After being convicted of manslaughter in the second degree, the judge sentences Warren Abbott to a maximum term of seven years in prison; McCoy makes the comment "wanna bet he doesn't even do that much?". Manslaughter in the second degree is a class C felony, it has a maximum possible sentence of 15 years in prison, but only a mandatory minimum sentence of 3-1/2 years. Since Abbott doesn't have a prior criminal record, he very likely would be released on parole after serving the minimum prison term of three and a half years, assuming his behavior as an inmate is good.Although having a violent felony conviction on one's record has serious consequences that last the rest of one's life, although for someone like Abbott the consequences are less serious, unless he had political aspirations. A felony conviction bars a person from voting, serving on a jury, serving in the military, severely limits the number of public offices a person can hold, severely limits employment opportunities and prevents any employment that requires being licensed/bonded or passing a background check, can make a person ineligible for certain government benefits (public housing, food stamps, SSI, cash grants), makes it very difficult to obtain international travel visas, and causes a person to forfeit their constitutional right to bear arms and own firearms. Additionally, a violent felony conviction holds even more serious consequences, most states have provisions for someone convicted of a non-violent felony to petition the court to have their record expunged and their rights restored after having a clean record for a certain period of time (10-20 years); Wyoming passed a law in 2023 that automatically restores the rights of a person convicted of a non-violent felony after 20 years, if they have no subsequent criminal convictions, and allows for them to file a petition after 10 years, several other states are considering similar laws. However there isn't any such provisions for those with a violent felony conviction, while it is technically possible for a violent felon to petition to get their record expunged, it is extremely rare for the petition to be granted. A violent felony conviction also bars a person from running for or holding any kind of public or political office.

Monster

1. This was Carey Lowell's last episode as a regular cast member. She would later guest star in three episodes as the same character, Jamie Ross.
2. This episode appears to be based on two separate cases:
   • The 1994/1997 Megan Kanka case. Seven-year-old Megan Kanka was raped and murdered by her neighbor, Jesse Timmendequas, after he lured her into his house; Timmendequas had previously been convicted of child molestation. The murder attracted national attention and subsequently led to the introduction of "Megan's Law", which requires law enforcement to disclose details relating to the location of registered sex offenders. In 1997, Timmendequas was convicted of Kanka's murder. He was initially sentenced to death, but his sentence was commuted to life without parole after New Jersey abolished capital punishment in 2007.
   • The 1997 Shatoya Currie (a.k.a. "Girl X") case, whose name at the time was not released. In 1997, a 9-year-old, known as Girl X, was raped, poisoned and dumped in a Cabrini-Green stairwell. Her assailant, Patrick Sykes -who will spend the rest of his life in a federal prison in Pontiac.
3. Edwards v. Arizona, 451 U.S. 477 (1981) was argued before the Supreme Court of the United States on November 5, 1980 and was decided on May 18, 1981. The case involved Robert Edwards being arrested for burglary, armed robbery, and murder in the first degree. During questioning Edwards told police he wanted to make a deal in exchange for the DA not seeking the death penalty, but told police that he would only talk with a lawyer present. The police put Edwards in lockup until a public defender could be assigned, police came and talked to him the following morning while he was still waiting for a lawyer. At first Edwards said he didn't want to talk to them, but police told him that his time to make a deal was running out, so Edwards agreed to speak with the police. They read him his rights again and after further questioning he confessed. At his trial Edwards tried to have his confession suppressed, the trial judge denied his motion, and the Arizona Court of Appeals & Arizona Supreme Court both denied his appeals. When Edwards' case went before the Supreme Court of the United States, they ruled 9-0 that Edwards' confession was obtained illegally and should have been suppressed, and vacated his conviction. The Court held that when a defendant invokes his Fifth Amendment right to counsel, police may not re-initiate custodial interrogation without counsel present or a knowing and intelligent relinquishment of that right. In his majority opinion, Justice White said "a waiver of the right to counsel, once invoked, not only must be voluntary, but also must constitute a knowing and intelligent relinquishment of a known right or privilege. The fact that Edwards confessed after being read his Miranda rights does not demonstrate that he understood his right to counsel and intelligently and knowingly relinquished it. Once the right to counsel under the Fifth Amendment has been invoked, a valid waiver cannot be shown just by the accused responding to interrogations despite Miranda warnings having been read"; the Court determined that the police's statement about Edwards having to speak to them because of a time limit on the deal, prevented Edwards from "knowingly and intelligently" waiving his right. Following this ruling police could no longer use deceit, lies or trickery in an attempt to get a suspect to waive their right to counsel, which is essentially what Briscoe and Curtis do in this case.
4. James Murtaugh has played six different characters over the course of the series:
   • Episode 1.4 Kiss the Girls and Make Them Die (1990) - Christianson.
   • Episode 3.11 Extended Family (1993) - Dr. Jenner.
   • Episode 6.2 Rebels (1995) - Dr. Farnsworth.
   • Episode 7.8 Family Business (1996) - David Solomon.
   • Episode 8.24 Monster (1998) - Newton.
   • Episode 19.5 Knock Off (2008) - Judge Samuel Sorotsky.
5. William Hill has portrayed seven different characters throughout the course of the series:
   • Episode 2.11 His Hour Upon the Stage (1991) - Hopkins.
   • Episode 2.19 The Fertile Fields (1992) - Hopkins.
   • Episode 3.12 Right to Counsel (1993) - Milgrim.
   • Episode 4.7 Apocrypha (1993) - Hines.
   • Episode 7.9 Entrapment (1997) - Eddie Page.
   • Episode 8.24 Monster (1998) - Kusevitsky.
   • Episode 10.12 Mother's Milk (2000) - Beltran's Lawyer.
   • Episode 12.5 Possession (2001) - Havel's Lawyer.
   • Episode 19.4 Falling (2008) - Eddie O'Connor.
6. Thom Sesma has played four different characters over the course of the series:
   • Episode 3.4 The Corporate Veil (1992) - Dr. Blum.
   • Episode 4.21 Doubles (1994) - Tom Boden.
   • Episode 8.24 Monster (1998) - Mark Considine.
   • Episode 14.1 Bodies (2003) - Detective Ed Goldstein.
7. Mark Lotito has played six different roles over the course of the series:
   • Episode 3.20 Securitate (1993) - Bailey.
   • Episode 4.4 Profile (1993) - Policeman #1.
   • Episode 5.1 Second Opinion (1994) - Paramedic.
   • Episode 6.18 Atonement (1996) - Nance.
   • Episode 8.21 Bad Girl (1998) - Detective Mallory.
   • Episode 8.22 Damaged (1998) - Detective Mallory.
   • Episode 8.24 Monster (1998) - Detective Mallory.
   • Episode 13.7 Open Season (2002) - Bartender.
8. Lennie's daughter Cathy Briscoe was born on June 23, 1971, and she was murdered on March 4, 1998. Per IMDb, the actress who played her, Jennifer Estlin, was actually born on November 21, 1964.