Law & Order

Season 9

Cherished

1. Atypical teratoid growths, now known as atypical teratoid rhabdoid tumors (AT/RT), are rare tumors that are usually diagnosed in early childhood. These tumors were first discovered in 1996, so at the time of this episode not much were known about them. Although they usually occur in the brain, they can occur anywhere in the central nervous system, including the spinal cord as with the baby girl in this episode. Tumors in that area are very rare, with only 2% of AT/RT's found in the spine. In the United States, three children per 1,000,000 or around 30 new AT/RT cases are diagnosed each year. Pediatric brain cancer is the second-leading cause of childhood death, just after leukemia. At the time this episode takes place, in 1998, a diagnosis of AT/RT was pretty much a death sentence, but as of 2018 the survival rate for AT/RT with early diagnosis is 60%.
2. Due to legislation passed by the United States government as of January 1, 2014 it is unlawful for insurance companies to deny coverage based on a preexisting medical condition.
3. Fatty-acid oxidation disorder, now known as Fatty-acid metabolism disorder, is a classification of genetic disorders that leave the body unable to produce energy within the liver and muscles from fatty acid sources. The body's primary source of energy is glucose; however, when all the glucose in the body has been expended, a normal body digests fats. Individuals with a fatty-acid metabolism disorder are unable to metabolize this fat source for energy, halting bodily processes. Most people with a fatty-acid metabolism disorder are able to live a normal active life with simple adjustments to diet and medications.
4. Intraventricular hemorrhage is when a blood vessel bursts and bleeds into the brain's ventricular system, which is a set of four interconnected cavities (ventricles) in the brain, where cerebrospinal fluid (CSF) is produced. It can result from physical trauma to the head or from a stroke.
5. Abby Carmichael transferred from "Special Narcotics," where she worked for four years and had a 95% conviction rate.
6. Adam Schiff held off the challenge from Judge Gary Feldman for re-election to District Attorney from the previous season.
7. First appearance of Assistant District Attorney Abby Carmichael (Angie Harmon ) in Law & Order.
8. At one time in this episode, Abbie says, "We're not talking about a couple of teenagers who killed their newborn because they were scared." Interestingly enough the episode Denial (1997) dealt with that exact situation.
9. Guest actor Edward Conery (spelled with one 'n') plays a character named Edward Connery (with two 'n's).
10. Kevin Elden has played five different roles over the course of the series:
    • Episode 9.1 Cherished (1998) - Oscar Castellano
    • Episode 9.14 Sideshow (1999) - CSU Detective Kett
    • Episode 10.1 Gunshow (1999) - Dan Hayala
    • Episode 11.21 Brother's Keeper (2001) - Payton
    • Episode 14.8 Embedded (2003) - Bernie
11. Graham Winton has played three different roles over the course of the series:
    • Episode 9.1 Cherished (1998) - Mr. Waring.
    • Episode 13.7 Open Season (2002) - Kevin Wilson.
    • Episode 19.12 Illegitimate (2009) - Jimmy McIntyre.
12. Joe Grifasi plays the part of James Linde in this, and two other, episodes, Previously, in episode 2.8 Out of Control (1991), he played the role of Ezra Gould.
13. This episode appears to be based on several separate cases/incidents:
    • The Beth Thomas case.
    • The crimes and legal statutes of child selling and adoption fraud.
    • The child laundering crisis.
14. In 1998 New York had one of the lowest minimum ages for juvenile delinquency in the US, children as young as 7 could be arrested for a criminal act and be tried in a criminal court of law as a juvenile delinquent. That changed in 2021 when New York legislature passed a new law that raised the minimum age a child could be charged as a juvenile delinquent to 12. For crimes committed by children under the age of 12, law enforcement will refer them to social services instead of arresting them and remanding them to family court, unless the crime committed was a homicide. By raising the minimum age to 12, the law aims to reduce the trauma and negative impacts of early criminalization. Advocates for the change cited research indicating that early involvement in the criminal justice system can increase the likelihood of future criminal behavior. The law also created the status of Adolescent Offender, which applies to minors who are 16-17 years of age, under the Adolescent Offender guidelines 16 and 17-year-olds charged with misdemeanors under the penal law are considered Juvenile Delinquents and their cases are decided in the Family Court, 16 and 17-year-olds charged with misdemeanors under the Vehicle and Traffic Law (speeding, distracted driving etc) are considered adults and their cases are decided in the local criminal court, and 16 and 17-year-olds charged with felonies are considered Adolescent Offenders, if their cases are removed from the Youth Part in Supreme or County Court to Family Court, they will then be considered Juvenile Delinquents. If a 16 or 17-year-old is convicted of a felony (that is not a homicide) as a Adolescent Offender in the Supreme Court, or County Court, and they successfully serve their jail and/or probation time with no violations, or without being arrested for another crime, their conviction will be voided and their record expunged.
15. McCoy says that "CPL 2010 sub three" gives him the jurisdiction to charge Dr. Kostov, even though the original crime occurred in Russia, outside the normal jurisdiction of a New York state or United States federal court. McCoy is referring to Article 20 of the New York Criminal Procedure Law, the CPL outlines the rules and processes for how criminal cases are handled within the justice system, from arrest to trial and appeal. Article 20, Section 10 (CPL 20.10) deals with geographical jurisdiction, it contains the procedures for determining if a particular crime falls under the jurisdiction of federal, state, county, or city courts & law enforcement. Subsection 3 (CPL 20.10 sub three) deals with result offenses, it states: "When a specific consequence, such as the death of the victim in a homicide case, is an element of an offense, the occurrence of such consequence constitutes the 'result' of such offense. An offense of which a result is an element is a 'result offense'". Furthermore, CPL 20.20, Subsection 2, Paragraph (a) states: "A person may be convicted in the criminal courts of this state of an offense defined by the laws of this state, committed either by his own conduct or by the conduct of another for which he is legally accountable...even though none of the conduct constituting such offense may have occurred within this state, if the offense committed was a result offense and the result occurred within this state. If the offense was one of homicide, it is presumed that the result, namely the death of the victim, occurred within this state if the victim's body or a part thereof was found herein"; in other words if a crime was committed in another jurisdiction, like neglect or assault, resulting in a person being gravely injured, and they die within the state of New York, whichever county they die in has jurisdiction over prosecuting them, even if the crime that caused their death occurred outside the jurisdiction.On a related note, CPL Article 20, Section 30 deals with the crimes of attempt, conspiracy, and criminal facilitation where only part of the crime was committed within the state, such as Dr. Kostov conspiring in Russia to commit the crimes he's charged with. CPL 20.30 sub one states: "Notwithstanding the provisions of section 20.20, the courts of this state do not have jurisdiction to convict a person of an alleged offense partly committed within this state but consummated in another jurisdiction, or an offense of criminal solicitation, conspiracy or attempt in this state to commit a crime in another jurisdiction, or an offense of criminal facilitation in this state of a felony committed in another jurisdiction, unless the conduct constituting the consummated offense or, as the case may be, the conduct constituting the crime solicited, conspiratorially contemplated or facilitated, constitutes an offense under the laws of such other jurisdiction as well as under the laws of this state". Which is a very long winded and technical way of saying a person can be charged with an attempt to commit a crime, conspiracy, or solicitation, if their conduct is also a crime in both New York and the jurisdiction where it was planned, or initiated.
16. Mike Burstyn makes an appearance. He is a well known Yiddish, and Hebrew singer, and film/stage actor.
17. Graham Winton's character is credited as Mr. Waring but his wife calls him Phillip.

DWB

1. The title of the episode 'DWB' is an abbreviation meaning Driving While Black.
2. After finding out that Officer Dietrich, their star witness, is actually the most racist of the three officers under indictment, McCoy says "I bought a pig in a poke". The phrase originates from medieval England, its earliest known use was in the early 1500's. It is referring to the medieval practice of merchants selling freshly slaughtered piglets, their meat was considered a delicacy in medieval Europe, especially amongst the elite and for special occasions. The piglets would be sold in cloth bags, called "pokes" in Middle English, to make them easy to carry, and to keep flies and other insects off the meat. Unscrupulous sellers would substitute a less valuable animal, like a cat or large rat, for the piglet, hoping the buyer wouldn't inspect the contents of the poke before purchasing. As such the phrase came to mean purchasing an item without inspecting it or doing proper research first, and also to refer to impulsive purchases. It was essentially a medieval version of the modern phrases "buyer beware" and "buyer's remorse".
3. This episode appears to be based on the following:
   • The 1991 Rodney King beating case. King was an African American taxi driver who became nationally known after being beaten by Los Angeles Police Department officers following a high-speed car chase on March 3, 1991. A witness, George Holliday, videotaped much of the beating from his apartment balcony and sent the footage to local news station KTLA. The footage shows four officers surrounding King, several of them striking him repeatedly while other officers stood by. Parts of the footage were aired around the world and raised public concern about police treatment of minorities in the United States. Four officers were charged with assault with a deadly weapon and use of excessive force. Three were acquitted of all charges. The jury acquitted the fourth of assault with a deadly weapon but failed to reach a verdict on the use of excessive force. The jury deadlocked at 8-4 in favor of acquittal at the state level. The acquittals are generally considered to have triggered the 1992 Los Angeles riots, in which 55 people were killed and over 2000 were injured, ending only when the California national guard was called in. The acquittals also led to the federal government's obtaining grand jury indictments for violations of King's civil rights. The trial of the four officers in a federal district court ended on April 16, 1993: two officers were found guilty and subsequently imprisoned, while the other two were acquitted again.
   • The 1998 James Byrd, Jr. case. In June 1998 in Jasper, TX, an African-American, James Byrd, Jr., was horrifically lynched-by-dragging by three white men. They tied Byrd's ankles to the bumper of a pickup truck & dragged him down an asphalt road for 3 miles. Byrd was conscious until his right arm & head were severed from his body about halfway down the road. The killers left his torso at a black cemetery. One killer, Shawn Berry, was executed in 2011. Another, John King, was executed in April 2019. The third, Lawrence Brewer, received a sentence of life imprisonment & will be eligible for parole in 2038. No motive for the murder has ever been revealed. Early in this episode, a black pastor mentions "Jasper" to Van Buren.
   • The 1955 Emmett Till case. Till was an African American boy who was abducted, tortured, and lynched in Mississippi in 1955 at the age of 14, after being accused of offending a white woman, Carolyn Bryant, in her family's grocery store. The brutality of his murder and the acquittal of his killers drew attention to the long history of violent persecution of African Americans in the United States. Till posthumously became an icon of the civil rights movement
   • The term "driving while black".
   • The term "blue wall of silence".
4. In 2002 a New York state court ruled that private citizens were not allowed to prosecute criminal charges because it violates a defendant's right to due process.
5. In the opening scene Lenny Briscoe checks out the victim's old Bulova watch and says, "It stopped tickin' when he took a lickin'".This is a reference to Timex watches (not Bulova). Their slogan, "Takes a lickin' and keeps on tickin'" alluded to the durability of their watches. The famous line was usually uttered by John Cameron Swayze, who even appeared in a commercial where he abused a couple watches to demonstrate their hardiness.
6. Marilyn Chris and John Ventimiglia previously appeared as mother and son in the episode called Bitter Fruit. They share no scenes in this episode.
7. John Ventimiglia has played four different roles over the course of the series:
   • Episode 5.4 Family Values (1994) - Gaydos.
   • Episode 6.1 Bitter Fruit (1995) - Nick Capetti.
   • Episode 9.2 DWB (1998) - Officer Frank Dietrick.
   • Episode 19.15 Bailout (2009) - Attorney Dibbens.
   • Episode 20.19 Crashers (2010) - Attorney Dibbens.
8. Michael McCormick has played four different roles over the course of the series:
   • Episode 6.7 Humiliation (1995) - Marty Gerber.
   • Episode 9.2 DWB (1998) - Dietrick's Attorney.
   • Episode 12.23 Oxymoron (2002) - Nicky Avakian's Attorney.
   • Episode 19.7 Zero (2008) - Judge Mark Brannigan.
9. If DA Schiff had seceded jurisdiction of the murder to the U.S. Attorney for the Eastern District of New York, the cops who did this would have easily qualified for a federal death penalty. First, the murder qualified as a hate crime: 18 U.S. Code § 249, Subsection 1, Paragraph B, along with Subsection 6, state: "Whoever, whether or not acting under color of law, willfully causes bodily injury to any person or, through the use of fire, a firearm, a dangerous weapon, or an explosive or incendiary device, attempts to cause bodily injury to any person, because of the actual or perceived race, color, religion, or national origin of any person is guilty of a hate crime and...shall be imprisoned for a minimum term of 30 years to life, if the defendant intended to cause serious physical injury, and death results from the offense". The manner in which the victim was killed also constitutes murder in the first degree, 18 U.S. Code § 1111, Paragraph (a) states: "Murder is the unlawful killing of a human being with malice aforethought. Every murder perpetrated by poison, lying in wait, or any other kind of willful, deliberate, malicious, and premeditated killing is murder in the first degree"; and paragraph (b) states: "Within the special maritime and territorial jurisdiction of the United States, Whoever is guilty of murder in the first degree shall be punished by death or by imprisonment for life". Additionally 18 U.S. Code § 3591 outlines the circumstances when the death penalty applies, of which several apply to this case, Subsection 2 states: "A defendant who has been found guilty of murder in the first degree, AND when a jury has determined beyond a reasonable doubt that the defendant (A) intentionally killed the victim; or (B) intentionally inflicted serious bodily injury that resulted in the death of the victim; or (D) intentionally and specifically engaged in an act of violence, knowing that the act created a grave risk of death to a person, other than one of the participants in the offense, such that participation in the act constituted a reckless disregard for human life and the victim died as a direct result of the act...shall be sentenced to death if, after consideration of the mitigating & aggravating factors set forth in section 3592, the jury finds that the death penalty is warranted". The aggravating factors under 18 U.S. Code § 3592 that apply are Subsection C, Paragraph 6: "The defendant committed the offense in an especially heinous, cruel, or depraved manner in that it involved torture or serious physical abuse to the victim" and Paragraph 9: "The defendant committed the offense after substantial planning and premeditation to cause the death of a person". Dragging a person, who has been specifically targeted, behind a car down a gravel road takes planning and premeditation, it constitutes a grave risk of death and a reckless disregard for human life, and constitutes torture & serious physical abuse, and dragging that person for over half a mile shows a clear, premeditated intent to cause the death of that person.
10. In the cases of Counselman v. Hitchcock (1892) & Brown v. Walker (1896), the Supreme Court of the United States first held that it is not unlawful or unconstitutional for an offer of transactional immunity to be granted to a witness in exchange for their truthful testimony. This ruling has been upheld by numerous subsequent state and federal courts including: Stewart v. United States (1971) originating in the United States District Court for the Central District of California, upheld by the United States Court of Appeals for the Ninth Circuit; Kastigar v. United States (1972) in the Supreme Court of the United States; United States v. McDaniel (1973) in the United States Court of Appeals for Eighth Circuit; United States v. Pantone (1980) in the United States Court of Appeals for the Third Circuit; State v. Soriano (1984) in the Oregon Court of Appeals; United States v. North (1990) in the United States Court of Appeals for the District of Columbia Circuit; and State v. Bervlis Consulting, LLC (2019) in the Washington Supreme Court.

Bait

1. Last appearance of John Fiore as Detective Tony Profaci.
2. This episode appears to be based on the Chad MacDonald case. On January 5, 1998, 17-year-old MacDonald was arrested (methamphetamine possession) in Brea, California, and agreed to become a police informant. Brea Police Dept (BPD) told MacDonald that if he volunteered to work as a drug informant, they would explain to the DA that he was fully cooperating, thus increasing his chance for a reduced sentence. MacDonald provided information about drug sales, and made one undercover methamphetamine purchase. On January 19th, police arrested Daryl William Hood and Ryan Patrick McGreevy in their "meth lab" based on info from MacDonald. When BPD discovered MacDonald using and selling methamphetamine outside the agreement, they terminated his CI status. Ten days later, on March 1st, MacDonald and his girlfriend (whose name was withheld due to being a minor) went to a Norwalk home where she was raped and shot, but survived. MacDonald was found dead in a Los Angeles alley on March 3rd. Cindy MacDonald, Chad's mother, claims that her son was forced into becoming a CI out of fear of a harsh sentence. She signed a police waiver allowing Chad to act as a CI. Taped conversations between MacDonald and BPD indicate that Chad felt endangered by his reputation as a CI shortly before he was killed. BPD suspected three other people that Chad informed on: Jose Ibarra, Michael Martinez and Florence Noriega, of kidnapping him and his girlfriend, and forcing him to watch her be raped and killed, as payback.Update: Shortly after this episode was filmed three people were arrested and charged for MacDonald's murder, and the attempted murder and rape of his girlfriend. Jose Ibarra, 21, Michael Martinez, 22, and Florence Noriega, 30, were arraigned in California Superior Court for the County of Norwalk on charges of robbery in the first degree, kidnapping in the first degree, rape in the first degree, accomplice to kidnapping and rape, attempted murder in the first degree, and murder in the first degree with special circumstances of using a firearm, use of a deadly weapon, and inflicting great bodily harm, which qualified all three defendants for the death penalty. In November of 1999 a jury found all three defendants guilty of all charges, however they were unable to reach a unanimous verdict on the death penalty. In January of 2000, a Superior Court judge sentenced Jose Ibarra to four consecutive terms of life in prison, plus 45 years for rape and kidnapping; Florence Noriega was sentenced to three consecutive life terms, plus 51 years for kidnapping, accomplice to rape, and attempted murder; Michael Martinez was sentenced to two consecutive life terms, plus 38 years for robbery and accomplice to kidnapping. The judge commented on how the defendants had shown no remorse at all, and on the fact that during the sentencing hearing the three of them were talking to each other and laughing, the judge also commented prior to pronouncing his sentence that he felt it was unfortunate the jury could not reach a consensus on the death penalty, because rarely had he seen three people who so richly deserved the harshest punishment the law allows. Their lawyers appealed their convictions to the California Court of Appeals, who denied their motion for appeal, and appealed the sentence to the California Supreme Court, the court declined to even review their case; they also unsuccessfully filed a writ of habeas corpus with the United States Court of Appeals for the Ninth Circuit, the court agreed to review the writ, but found that none of their civil rights under the U.S. Constitution were violated and ordered the convictions and sentences to stand. With no avenues of appeal remaining the three will die in prison.
3. During this episode Briscoe reveals that McCoy's father was a cop in Chicago, not New York.
4. David Adkins (Dr. Lesser) also played the part of Williamson in episode 14.14, City Hall (2004).
5. Sara Teasdale, the name of the female shooting victim in this episode, is also the name of a well-known 20th century American poet.
6. John Jellison has played three different roles over the course of the series:
   • Episode 9.3 Bait (1998) - Mr. Teasdale.
   • Episode 11.10 Whose Monkey Is It Anyway? (2001) - Paul Marra.
   • Episode 14.19 Nowhere Man (2004) - Mike O'Dwyer.
7. Jerry Orbach and Sam Waterston appeared together in Woody Allen's Crimes and Misdemeanors (1989).

Flight

1. This is a very early career, 1 min scene, for Jim Gaffigan. He was the plumber in the white shirt.
2. Toward the end of the episode, McCoy tells Schiff he wants to sue Elgin, the supplier of the virus. Schiff asks if they prosecute gun manufacturers when someone is shot. In the next season, McCoy does exactly that, in the episode titled Gunshow (1999).
3. Dylan Baker has portrayed three different characters throughout the series:
   • Episode 2.11 His Hour Upon the Stage (1991) - Sean Hyland.
   • Episode 9.4 Flight (1998) - Aaron Downing.
   • Episode 14.11 Darwinian (2004) - Sanford Rems.
   • Episode 15.10 Enemy (2004) - Sanford Rems.
   • Episode 16.20 Kingmaker (2006) - Sanford Rems.
4. Vancomycin-resistant Staphylococcus aureus (VRSA) is a close, more aggressive cousin, to the more common Methicillin-resistant Staphylococcus aureus (MRSA), which are both aggressive, antibiotic resistant strains of staphylococcus aureus (staph). Staph infections are typically treated with penicillin-class antibiotics, and very specific penicillin derivatives were created to treat staph infections, the two most commonly used are methicillin and oxacillin, which were developed around 1960, although staph infections had been treated with penicillin since its discovery in 1923. After decades of being exposed to antibiotics like penicillin and methicillin, with many of these antibiotic exposures being needless, the staph bacteria began to mutate and become resistant to these types of antibiotics, hence in 1961 a new strain of staph was discovered: Methicillin-resistant Staphylococcus aureus. It was discovered around 1970 that the antibiotic vancomycin, which has a different mechanism of action than methicillin, was effective at treating MRSA infections and proved to be a reliable treatment option for a number of years. The problem is vancomycin is also used to treat a number of infections like skin infections, bloodstream infections, endocarditis, bone and joint infections, and meningitis. In 1996, doctors in Japan discovered a new strain of staph that was resistant to vancomycin, hence it was called Vancomycin-resistant Staphylococcus aureus. VRSA cases were reported in Western Europe in 1998, and the first recorded case of VRSA in the United States was in Michigan in 2002. VRSA is a very difficult infection to treat, but in recent years doctors have found success in treating it with newer generation antibiotics like daptomycin, linezolid, telavancin, ceftaroline and quinupristin-dalfopristin, though it's only a matter of time before the staff bacterium starts to adapt to these as well. As of 2019, 52 VRSA strains have been identified in the United States, Japan, India, Iran, Pakistan, France, Brazil, and Portugal.
5. Jack Gilpin plays Attorney Axtell in this episode & three others. Previously, he played the role of Dr. Simon Reed in episode 5.12, Progeny (1995).
6. J. Smith-Cameron has played four different characters over the course of the series:
   • Episode 2.13 Severance (1992) - Ms. Moskowitz.
   • Episode 9.4 Flight (1998) - Paula Downing.
   • Episode 14.5 Blaze (2003) - Linda Drosi.
   • Episode 19.16 Take-Out (2009) - Attorney Ward.
7. This episode appears to be based on the Brian Stewart case.
8. John Dossett has played four different characters over the course of the series:
   • Episode 3.19 Virus (1993) - Don Stuart.
   • Episode 9.14 Sideshow (1999) - Frank Wellington.
   • Episode 12.11 The Collar (2002) - Father Evans.
   • Episode 16.3 Ghosts (2005) - Judge Martin Schnell.
9. Schiff says that companies make choices every day that inadvertently get people killed, "a car company chooses to save a few bucks on a cheaper brake system, and a few hundred people die as a result". McCoy replies with "but a car isn't a deadly weapon". However a car can absolutely be a deadly weapon in the wrong hands, many things can be, and the responsibility ultimately lies with the person that makes the choice to kill, not the company that made the inanimate object they used (so long as it was made in compliance with the law). The FBI's NCIC (National Crime Information Center) crime statistics show that from 2013-2023, 1,575 intentional homicides (murder & voluntary manslaughter) were committed where the weapon used to kill was a motor vehicle or vessel; more people were murdered with a car, than with: automatic handguns (1,508), shotguns (1,383), drugs (1,228), asphyxiation (752), fire/incendiary devices (623), automatic rifles (279), and poison (99).
10. The past, and sometimes still current, frivolous use of antibiotics is largely to blame for the existence of MRSA and VRSA, doctors used to routinely prescribe antibiotics to treat viral infections like the common cold and influenza, at one time it was thought antibiotics worked on viruses, although that was disproven decades ago. Yet doctors continued to prescribe antibiotics for viral infections well into the 1990's, largely because the myth about antibiotics helping shorten the duration of the cold or flu persisted, and doctors prescribed them simply because patients asked for them. Thankfully the CDC's public service education program about not using antibiotics for the cold and flu helped dispel that myth. But the needless use of antibiotics is still seen with antibiotic soaps, and antibiotic hand sanitizer (regular soap & alcohol based sanitizers work just fine), the staph bacteria is commonly found in humans and exposure to even over-the-counter antibiotics can help give it antibiotic resistance, and this is the same for many types of bacteria. The panic surrounding the COVID-19 pandemic inadvertently made things even worse for the spread of antibiotic resistant bacteria, once again the myth about antibiotics and viruses resurfaced, despite the fact that the coronavirus is well, a virus, antibiotic hand sanitizers began flying off store shelves, and people were panic buying antibiotic sanitizing wipes almost as much as they did toilet paper. Since the 1990's even more types of antibiotic resistant bacteria have been created including Vancomycin-Resistant Enterococci (VRE), Carbapenem-resistant Enterobacterales (CRE), and an especially dangerous one is Multidrug-resistant tuberculosis (MDR-TB). Public health and epidemiology experts fear that the overuse of antibiotics, especially OTC ones, will eventually lead to antibiotics becoming useless.

Agony

1. This episode appears to be based on the Ted Bundy case.
2. The only episode where the detectives, the medical examiner, and the district attorneys all appear in the same scene.
3. During their argument about how to prosecute Bergstrom, Abbie reminds Jack McCoy he once hid a witness to get the result he wanted. This is in reference to the season 8 episode Under the Influence (1998), where McCoy told a witness to leave the country after making a statement. In the season 8 finale episode Monster (1998), McCoy was called before the Disciplinary Committee of the New York Bar Association regarding his unethical conduct in that case, it ends on a cliffhanger with McCoy walking into the room. The disciplinary action taken against McCoy isn't learned until the season 16 finale episode Invaders (2006), when McCoy yet again is called before the Committee and nearly loses his license; that episode revealed that he was fined and placed on a five year probationary period in which any additional ethical violations would have automatically disbarred him.
4. Christopher Patrick Mullen, who plays serial killer Matt Bergstrom, plays a lawyer two seasons later in Whiplash (2001).
5. Mark Blum has played three different characters over the course of the series:
   • Episode 3.16 Jurisdiction (1993) - A.D.A. Frank Lazar.
   • Episode 5.15 Seed (1995) - Michael Aronson.
   • Episode 9.5 Agony (1998) - Frank Lazar.
   • Episode 20.5 Dignity (2009) - Expert Doctor.
6. John Leonard Thompson has played three different roles over the course of the series:
   • Episode 6.4 Jeopardy (1995) - Gil.
   • Episode 9.5 Agony (1998) - Sam Franklin.
   • Episode 15.15 Obsession (2005) - Jake Lippman.

Scrambled

1. The episode appears to be based on the 1998 Kass v. Kass case. The case involved the disposition of frozen pre-embryos, it was the first time a New York state court (or any U.S. court) dealt with this issue, it specifically dealt with whether an agreement made as part of a divorce proceeding was valid, binding, and legally enforceable in determining the disposition of the pre-embryos. The court ultimately determined that it was, since it didn't involve the issue of a woman's right to bodily privacy and integrity, and because pre-embryos are not considered persons under New York state law, or federal law.The case began as a typical divorce case in the New York Supreme Court. Maureen Kass and Steven Kass were married and, in an effort to have children, attempted in-vitro fertilization (IVF) procedures. The couple tried IVF unsuccessfully for five years, after deciding to cease implantation attempts, they were left with five frozen pre-embryos (fertilized embryos frozen before cellular division begins). The couple signed an agreement with the medical clinic that if they could not agree to the disposition of the pre-embryos, the pre-embryos would be donated to the IVF program for research after five years. Three weeks later, in anticipation of a divorce, the Kasses signed an additional agreement stating that the pre-embryos would be disposed of as described in the consent agreement and that neither of them would seek custody of the pre-embryos. Three weeks after that, Mrs. Kass filed for divorce, and also filed for sole custody of the pre-embryos for the purpose of implantation. Mr. Kass filed a motion challenging her custody request, and asked the court to enforce the two legal contracts they had previously agreed to, and signed. Considering the complex, and unprecedented issued this case dealt with, the divorce court judge remanded the case to the state's intermediate appellate court: the New York Supreme Court Appellate Division, Second Judicial Department. The Appellate Division's judges found that the contract the couple had signed was legally valid, and ordered its enforcement. Mrs. Kass filed an appeal of the ruling to the New York Court of Appeals for the Second Appellate Division (the highest court in the state), in the appeal she challenged the legality of the contract, arguing that it was unconstitutional since it dealt with what she considered to be "living persons". The Judges of the Court denied Mrs. Kass' motion, in a unanimous 7-0 decision they upheld the Supreme Court Appellate Division's ruling that the contract she signed was legally binding and enforceable. Chief Judge Judith Kaye wrote the court's opinion: "An agreement between the two biological donors regarding disposition of their pre-embryo is presumed valid and binding and should be enforced in the case of a dispute. Courts should balance the competing interests of the two parties unless there is a written agreement between the parties. When such an agreement exists, it should be presumed valid and implemented. A case regarding the disposition of pre-embryos does not involve a woman's right to privacy or bodily integrity and pre-embryos are not "persons" for constitutional [or legal] purposes. Therefore, the case is resolved by determining who has dispositional authority over the pre-embryos. The agreement signed by Plaintiff and Defendant answers that question. Therefore the Court orders the pre-embryos be donated to the appropriate research center, as stipulated in the contract".
2. Briscoe asks the CSU tech how cold the storage containers for the embryos are, the tech replies that they are stored in liquid nitrogen, which is cold enough to freeze and shatter your finger if you stuck it inside. The exact temperature of liquid nitrogen is between -346 °F and -320.44 °F (-210 °C and -196 °C). When nitrogen's temperature rises to or above -320.45°F (its boiling point) it becomes a gas and evaporates, and when nitrogen's temperature drops below -346.1 °F (freezing point) it becomes a solid.
3. Schiff asks how long the frozen embryos are viable for, Carmichael states that no one knows. There is no maximum shelf life for frozen embryos. Embryos are typically frozen using vitrification, a process that involves flash-freezing them in liquid nitrogen at extremely low temperatures, within a few minutes (at most) of the eggs being fertilized. This process effectively halts biological activity, allowing for long-term storage without degradation. So long as the embryos are kept frozen at minimum temperature of -135 °C (-211 °F), the optimum temperature is -196 °C (-320.44 °F), they are viable indefinitely, in theory a frozen pre-embryo could be successfully implanted well over a century after it was fertilized. There have been cases of live births from embryos frozen for over 20 years, the world record for the oldest viable frozen embryo to result in a live birth is 30.5 years; the record is held by a pair of fraternal twins born in October of 2022, their embryos had been in cryostorage since April of 1992.
4. Jordan Lage has played six different roles over the course of the series:
   • Episode 6.13 Charm City (1996) - Jury Foreman.
   • Episode 7.7 Deadbeat (1996) - Charles.
   • Episode 9.6 Scrambled (1998) - Dr. Harvey Purcell.
   • Episode 11.18 White Lie (2001) - Buddy Marks.
   • Episode 13.1 American Jihad (2002) - Jeff Bodner.
   • Episode 18.2 Darkness (2008) - William Tyrell.
   • Episode 19.21 Skate or Die (2009) - William Tyrell.
5. Mr. Chaikin agrees to plead guilty to attempted burglary in the third degree. Burglary in the third degree is sentenced as a non-violent class D felony, it carries a minimum penalty of 1-3 years probation (max probation is 7 years) and a fine of up to $5,000, for repeat felony offenders it carries a minimum sentence of 1-1/2 years in prison and a maximum sentence of seven years. Attempted burglary in the third degree is sentenced as a non-violent class E felony, it carries a minimum penalty of 1-2 years probation (max probation of 4 years) and a fine of up to $3,000, for prior felony offenders it carries a minimum sentence of 1-1/3 years in prison, and a maximum sentence of 4 years.

Venom

1. The episode appears to be based on the Sante and Kenneth Kimes trial.
2. Karen Ziemba's (Detective Tarvis) TV debut.
3. A witness says Mrs. Crosby's boyfriend rides an English motorcycle "like the ones the Tommies used in World War II". Tommy Atkins (often just Tommy) is slang for a common soldier in the British Army. It was a well established nickname by the late 19th century, and became especially popular during World War I. German soldiers would shout "Tommy" across no man's land (the space between enemy trenches) if they wished to speak to a British soldier. French and Commonwealth (Australia, Canada etc) troops would also call British soldiers "Tommies". The nickname became less common following World War II. Since the 21st century, the term Tommy Atkins has been used less frequently, although the name "Tom" is occasionally still heard; enlisted soldiers in the British Army's elite Parachute Regiment, 1st Battalion, Special Forces Support Group, are called "Toms".The etymology of the term is uncertain and there is debate about its origin, but it was used as early as 1743. It was used in a letter regarding a mutiny amongst British troops stationed in Jamaica in 1742, the mutiny was started by troops from the British colonies in North America, and was one of the early signs of the impending American Revolution. The author of the letter wrote "except for those from N. America ye Marines and Tommy Atkins behaved splendidly". A popular theory is the nickname originates from the heroic actions of multiple soldiers with the name, in England the first name "Tommy" and the last name "Atkins" are both fairly common. It is commonly believed the nickname was made popular in 1843 by Arthur Wellesley, 1st Duke of Wellington after he was inspired by the bravery of a soldier at the Battle of Boxtel in 1794 during the Flanders Campaign, which he mentioned in his memoirs; Duke Wellesley is best known for achieving the rank of Field Marshall (equivalent to a 5-star General), after playing a critical role in Napoleon's defeat at the Battle of Waterloo in 1815. At the Battle of Boxtel in 1794, Duke Wellesley was a Lieutenant Colonel in the Royal Army and was in command of the 33rd Regiment of Foot. Purportedly after a fierce battle the Duke spotted one of his men, Private Thomas Atkins, being seriously wounded. Wellesley stayed by Private Atkins' side while the unit surgeon attended him, when he expressed his regret for Atkins grave injury, Atkins replied "It's all right, sir. It's all in a day's work" and died shortly after.
4. John Cunningham has played five different characters over the course of the series:
   • Episode 18.4 Bottomless (2008) - Daniel Metzler.
   • Episode 12.12 Undercovered (2002) - Daniel Metzler.
   • Episode 9.22, Admissions (1999) - Mr. Crowley.
   • Episode 9.7 Venom (1998) - Daniel Metzler.
   • Episode 7.14 Working Mom (1997) - Daniel Metzler.
   • Episode 5.2 Coma (1994) - Max Weston.
   • Episode 3.18 Animal Instinct (1993) - Donald Walsh.
   • Episode 2.11 His Hour Upon the Stage (1991) - Cobb.
5. Jim DeMarse (Walter) also played the role of Ralph Walton in Episode 3.10, Consultation (1992).

Punk

1. This episode appears to be based on the 1974 Joan Little case. Joan Little an African-American woman was charged with the 1974 murder of Clarence Alligood, a white prison guard at Beaufort County Jail in Washington, North Carolina, who attempted to rape Little before she could escape. Her case became a cause célèbre of the civil rights, feminist, and anti-death penalty movements. Little was the first woman in United States history to be acquitted using the defense that she used deadly force to resist sexual assault. Her case also has become classic in legal circles as a pioneering instance of the application of scientific jury selection.
2. Luis Pacheco calls Briscoe and Curtis "maricóns" which is Spanish for "faggot" or "fairy".
3. In this episode, A.D.A. Carmichael describes her personal experience as a rape victim. The next year, the writers build on this character development when Angie Harmon guest stars in 6 episodes of the spin-off series, Law & Order: Special Victims Unit (1999).
4. Danielle Melnick tells McCoy that the law says a prison inmate can't consent to sex with a corrections officer, as it's statutory rape. She is specifically referring to New York Penal Law, Article 130, Section 25, Subsection 3, which states: "A person is guilty of rape in the third degree when: He or she engages in sexual intercourse with another person without such person's consent where such lack of consent is by reason of some factor other than incapacity to consent". "By reason of some factor other than incapacity" means that the person did not freely and voluntarily agree to the sexual activity, and this lack of agreement was due to something other than the person being unable to give consent due to factors like age or mental incapacity. This includes situations where consent is not freely given because of coercion, force, threats, or intimidation. Trial court judges in both New York county circuit courts, New York Supreme Court (and pretty much all state courts), and the United States District Court have consistently held that a prison inmate cannot freely and voluntarily consent to sex with a corrections officer because of the ease at which a corrections officer can coerce, intimidate, or threaten an inmate. These rulings have also been consistently upheld by both the New York Court of Appeals, the United States Court of Appeals, and even the Supreme Court of the United States.
5. Cara Buono has played three different roles over the course of the series:
   • Episode 6.20 Girlfriends (1996) - Shelly Taggert.
   • Episode 9.8 Punk (1998) - Alice Simonelli.
   • Episode 17.15 Melting Pot (2007) - Attorney Shannon.
6. Opal Alladin (Trina Fleming) also played the role of Rochelle Diggs in episode 12.16, Born Again (2002).
7. This episode appears to be based on the epidemic of prison rape in the U.S.
8. Socorro Santiago has played seven different characters over the course of the series:
   • Episode 2.5 God Bless the Child (1991) - Cora Amado.
   • Episode 5.19 Cruel and Unusual (1995) - Clarice Reynolds.
   • Episode 7.14 Working Mom (1997) - Teresa Regalado.
   • Episode 9.8 Punk (1998) - Alma Cabrera.
   • Episode 11.18 White Lie (2001) - Teresa Martinez
   • Episode 13.22 Sheltered (2003) - Mrs. Anna Rodriguez.
   • Episode 16.5 Life Line (2005) - Estela Richter.
9. Peter Van Wagner has played four different roles over the course of the series:
   • Episode 4.10 The Pursuit of Happiness (1993) - Stan Feldman.
   • Episode 6.20 Girlfriends (1996) - Jonathan Freeman.
   • Episode 9.8 Punk (1998) - Attorney for Pacheco.
   • Episode 10.22 High & Low (2000) - Jim Harris.
10. The victim in this episode is a Correctional Officer named "Charlie Tyner." This may be an intentional reference to actor Charles Tyner, whose first prominent role was as a prison guard in Cool Hand Luke.
11. Albion Correctional Facility is mentioned, which is a medium security prison for women in the Town of Albion, Orleans County, New York, located about 35 miles west of Rochester, New York. It sometimes gets confused with State Correctional Institution - Albion, a Medium-Security correctional facility for males, located in the extreme northwestern corner of the commonwealth of Pennsylvania in Erie County, about 30 miles southwest of the town of Erie, PA. Albion Correctional Facility, NY is located about 165 miles northeast of SCI Albion, PA.

True North

1. This episode appears to be based on two separate cases/incidents:
   • The 1995 Patrizia Reggiani (a.k.a. "The Black Widow") case. Reggiani, an Italian convicted criminal and former socialite, was convicted in a highly publicized trial of hiring a hitman to kill her ex-husband, Maurizio Gucci.
   • The 1999 Stanley Faulder case. Faulder was the first Canadian citizen to be executed in the United States since 1952. Faulder, a Jasper, Alberta native, was convicted of murdering Inez Scarborough Phillips, a 75-year-old woman, in Texas in 1975 during a robbery in her house. He was caught, convicted, and sentenced to death in 1977. Faulder had previously served three years in prison for auto theft in Canada. Despite diplomatic complaints by the Canadian government, Faulder was executed by lethal injection on June 17, 1999. His last appeal was rejected about an hour before his death.
2. The New York Court of Appeals, the state's highest court, declared capital punishment unconstitutional in 2004. Before that, the last person executed by NY State was in 1963. The death penalty for federal crimes committed in NY still exists, though the last federal execution for a federal crime committed in New York was in 1954. The Rosenbergs were federal executions carried out at Sing-Sing in 1953. In 2007, the New York Court of Appeals commuted all remaining death sentences handed down in New York state courts to life without parole. In 2008, the New York Bureau of Prisons dismantled all of the state prison's death chambers, and the death penalty was officially removed from both the New York Penal Law, and Criminal Procedure Law, statutes as a possible sentence for murder in the first degree and aggravated murder.
3. George Pataki was the governor when this was filmed in fall, 1998. The death penalty was imposed as a matter of course during his terms, but not carried out. As for Stephanie Harker, the last woman executed in NY State was Roxana Druse, convicted of murdering her husband, and hanged in 1887. Her hanging prompted NYS to adopt the electric chair in 1890. The last man executed by the state was Eddie Lee Mays, in 1963. These were/are separate and apart from federal executions carried out in, but not by, New York State.
4. As of December 23, 2024, there were forty federal inmates on death row. Before leaving office, President Joseph Biden used his executive authority to commute the death sentences of thirty-seven of them to life without the possibility of parole. As of July 2025, the three federal inmates still on death row are: Dzhokhar Tsarnaev, convicted in 2015 in the United States District Court for the District of Massachusetts on charges of domestic terrorism and murder for his role in the 2013 Boston Marathon Bombing, which killed three people. Dylann Roof, a Neo-Nazi and white supremacist convicted in 2017 in the District of South Carolina for the 2015 fatal shooting of nine parishioners in a church in South Carolina; he was also facing the death penalty in a South Carolina Superior Court, making him the first person in U.S. history to face a federal and state death sentence at the same time. Robert Bowers, yet another white supremacist, was convicted in 2023 in the Eastern District of Pennsylvania for the mass shooting at Tree of Life Synagogue, which left 11 dead. It is expected that President Donald Trump will sign Tsarnaev and Roof's death warrants during his second term. Although Bowers' case still has a pending appeal before the United States Court of Appeals for the Third Circuit and a potential appeal to the Supreme Court of the United States, it is unlikely for his death sentence to be finalized before President Trump's second and final term ends; although considering the extremely heinous nature of his crimes, it is very likely whoever is elected in 2028 will sign his death warrant.
5. Schiff mentions the extreme cost to the state when it comes to executing someone. Due to the extensive appeals process, it actually costs the state more to execute someone than it does to imprison them for life, but, as McCoy mentioned in a previous episode, some people are too evil to be left alive. When a person is convicted of capital murder and sentenced to death, their case is automatically appealed to a higher court to ensure that the facts of the case were correct and support the death penalty. When a death penalty is handed down by a state court, the automatic appeal is heard by that state's highest court, which, in New York, is the New York Court of Appeals; if the death penalty is pronounced by the federal United States District Court, the automatic appeal goes to the United States Court of Appeals. If the conviction and death penalty are affirmed by the automatic appeal, the defendant can then file a writ of certiorari with the Supreme Court of the United States, which is petitioning the court to review their case; however, the Supreme Court only reviews about two percent of the cases submitted to them each year. If the Supreme Court does accept the writ of certiorari and reviews the defendant's case and finds no issues and upholds the lower court's findings, that is the end of their avenues of appeal, since they are the highest court in the land. However, if the Supreme Court denies the writ of certiorari, the defendant can still file appeals in federal court. If the defendant's lawyer feels that the death penalty was improperly applied to their case and has evidence or case law to support their claim, they can file a writ of habeas corpus in District Court challenging the death penalty as being unconstitutional in their case. In Stephanie Harker's case, the writ of habeas corpus would be filed with the United States District Court for the Eastern District of New York; if the District Court denies the writ, an appeal can be filed with the United States Court of Appeals for the Second Circuit, and, if they deny it, one final appeal can be made to the Supreme Court of the United States. So, a death penalty case can have up to five avenues of appeal, which is why they are so expensive and why a person often spends at least a decade on death row before being executed.
6. As another item mentions, at the time of this episode's writing the federal government hadn't executed someone since 1963. Although in 1998 there were over two dozen inmates on death row in the federal prison system awaiting execution, such as Timothy McVeigh, who was sentenced to death in 1997 by the United States District Court for the Western District of Oklahoma for the Oklahoma City federal building bombing that killed 168 people. McVeigh was executed by lethal injection on June 11, 2001, making him the first person in 38 years to be executed by the federal judicial system. As of July, 2025, 15 additional people have been executed by the federal judicial system. In order for someone to be executed in the federal judicial system their death warrant must be signed by the President of the United States. Since 2001, there has been a total of 16 people executed by the federal judicial system, all by lethal injection, two were executed during President George H.W. Bush's term, and the other 14 during President Donald Trump's first term.They are as follows: Juan Raul Garza, drug lord and murderer, was executed on June 19, 2001 after being convicted in the United States District Court for the Southern District of Texas for murdering three police informants. Louis Jones Jr. on March 18, 2003 in the Northern District of Texas for the 1995 rape and murder of 19 year-old U.S. Army Private Tracie Joy McBride. Neo-Nazi and white supremacist Daniel Lewis Lee on July 14, 2020 in the Eastern District of Arkansas for murdering a black family of three during a home invasion robbery in 1996. Wesley Ira Purkey on July 16, 2020 in the Western District of Missouri for the 1998 rape and murder of 16-year-old Jennifer Long. Mass murderer and drug dealer Dustin Lee Honken on July 17, 2020 in the Northern District of Iowa for the 1993 murder of five people, one was a man testifying against him, the other four were the man's girlfriend and daughters. Lezmond Charles Mitchell on August 26, 2020 in the District of Arizona for the 2001 carjacking and murder of a 68 year-old Alyce Slim and her 9-year old granddaughter Tiffany Lee. Keith Dwayne Nelson on August 28, 2020 in the Western District of Missouri for the 1999 kidnapping, rape and murder of 10 year-old Pamela Butler. William Emmett LeCroy Jr. on September 22, 2020 in the Northern District of Georgia for the 2001 rape and murder of his 30 year-old neighbor Joann Lee Tiesler. Christopher Andre Vialva on September 24, 2020 in the Western District of Texas for the 1998 carjacking and murder of Iowa pastors Todd and Stacie Bagley (28 & 26). Orlando Cordia Hall on November 19, 2020 in the Northern District of Texas for the 1994 kidnapping, torture, gang rape and murder of 16 year-old Lisa Rene. Brandon Anthony Micah Bernard on December 10, 2020 in the Western District of Texas for participating in the 1998 murder of the Iowa pastors. Alfred Bourgeois on December 11, 2020 in the Southern District of Texas for the 2002 kidnapping, sexual assault, and murder of his 2 year-old daughter. Lisa Marie Montgomery on January 13, 2021 in the Western District of Missouri for the 2004 kidnapping and murder of pregnant 23 year-old Bobbie Jo Stinnett, whose baby she cut out of her womb to steal; Montgomery is the first woman to be executed by the federal government since 1953. Corey Johnson on January 14, 2021 in the Eastern District of Virginia for the 1992 murder of seven members of a rival drug gang, one victim was stabbed 82 times. Finally Dustin John Higgs on January 16, 2021 in the District of Maryland for the 1996 murder of three women.
7. John Doman played five different characters over the course of the series:
   • Episode 1.22 The Blue Wall (1991) - Bailiff.
   • Episode 7.20 We Like Mike (1997) - Sgt. Frank Gottlieb.
   • Episode 9.9 True North (1998) - Mr. Stephens.
   • Episode 13.18 Maritime (2003) - Howard Ridgeway.
   • Episode 18.6 Political Animal (2008) - Jim Gilles.
8. Guest star John Doman (Mr. Stevens) will guest star with Angie Harmon (A.D.A. Abbie Carmichael) again on the TNT show Rizzoli & Isles (2010). John Doman will play the character of Paddy Doyle, the biological father of Sasha Alexander's character Maura Isles.

Hate

1. The episode ends with a tribute to United States Attorney Charlie Rose, who died shortly after this episode was filmed: "Dedicated to United States Attorney CHARLES ROSE: He made the world a safer place". He worked for 15 years as an Assistant U.S. Attorney with the United States Attorney's office for the Eastern District of New York. During that time, he worked his way up the chain-of-command in the office, holding the titles of deputy chief and then chief of the office's narcotics section, chief litigator, and, at the time of his retirement, he held the title and position of Executive Assistant United States Attorney for the Eastern District of New York, making him the United States Attorney's second-in-command. That position is the federal equivalent to McCoy's position as the Executive Assistant District Attorney for New York County. EAUSA Rose helped prosecute bank robbers, narcotics traffickers, terrorists, and organized-crime figures. His biggest case was prosecuting terrorists from Puerto Rico who wanted their country to no longer be a territory of the United States: they had bombed the headquarters of the New York City Police Department and the F.B.I. headquarters at Federal Plaza. Mr. Rose prosecuted the terrorists responsible for the bombings and got convictions on all of them. In 1990, he prosecuted one of the largest cases involving organized crime since that of Al Capone: he prosecuted notorious mobster Vincent Gigante, who conspired with fourteen other reputed gangsters to rig bids and extort payoffs from contractors on multi-million-dollar bids with the New York City Housing Authority. Everyone charged was convicted on multiple counts of extortion, racketeering, and murder, except for Mr. Gigante who stalled his trial by pretending to be mentally unfit. However, he was eventually convicted, although it was after Mr. Rose left the U.S. Attorney's office. Charles Rose has been credited with doing more than any other U.S. Attorney (at the time of his death in 1998) to clean up organized crime in New York City.
2. This episode appears to be based on the following cases/incidents:
   • The 1988 murder of Mulugeta Seraw and the subsequent civil lawsuit against Tom Metzger. Metzger, who founded the White Aryan Resistance (WAR), was found guilty of inciting the murder of Ethiopian immigrant Mulugeta Seraw after three WAR members beat and kicked Seraw to death. Metzger was found guilty on civil rather than criminal charges. The three WAR terrorists received varying jail sentences for Seraw's murder. Metzger was bankrupted and must make payments, which are ongoing as of 2019.
   • The 1998 Kimberly Dotts murder case, which happened in Clearfield County (west-central Pennsylvania) that occurred shortly before this episode aired. Kimberly planned to run away to Florida with a group of newly-made friends (actually juvenile delinquents) who turned on her when they believed she would snitch on their plan. The group, lead by Jessica Holtmeyer, took Kim to a remote area of Bradford Township, known as Gallows Harbor, where they strangled and hanged her with a rope and then bludgeoned her to death with a basketball-sized rock. Holtmeyer was found guilty and sentenced to life in prison. However, as of October 2017, she may be re-sentenced according to a new law that precludes a life sentence for a juvenile offender, even retroactively. The crime puzzled some residents of Clearfield because Jessica came from a very good, well-liked, and well-respected family, active in the church and community. Others were not at all surprised: Jessica had a troubled childhood, and her mother would never have won a Parent of the Year award. One of the characters in this episode is called Jessica.
   • The National Socialist Movement political party.
   • The 1977 National Socialist Party of America v. Village of Skokie case.
   • The 1969 Brandenburg v. Ohio case.
   • The 1941 Milk Wagon Drivers v. Meadowmoor Dairies, Inc. case.
   • The ethical debate about redefining the limitations of freedom of speech to prevent incitement of violence.
3. The farm property where Lenny and Rey go with Pennsylvania State cops to arrest 4 members of the group who killed the girl is located in Nuremberg, PA. Nuremberg, Germany is where the Nazi war criminals were tried after World War 2. This story revolves around White Supremacists.
4. Second television appearance of future CSI: NY (2004) mainstay Anna Belknap, who played a teenager despite being 27 years old. Her first TV appearance was in Work Related (1996), where she also played a teenager.
5. The Pennsylvania State Police sergeant tells the skinhead to surrender the teenagers they have an arrest warrant for or else they will come in and arrest them by force and seize any illegal items they find, including the gatekeeper's "modified AK". Pennsylvania did not have any state laws at the time and still doesn't as of 2025, that outlawed "assault weapons". However, this episode takes place when the Federal Assault Weapons Ban of 1994 was in effect, which banned the civilian sale and transfer of certain semi-automatic rifles, like the AK-47 and AR-15, or any semi-automatic rifle which possess two or more features such as: detachable magazine, threaded barrel, folding stock, telescoping stock, pistol grip, flash suppressor, or silencer; although, it had a grandfather clause for rifles legally owned prior to 1994. The ban had a sunset clause and expired in 2004. So, everyone on the skinhead compound would have needed to prove they legally purchased their rifles prior to 1994, or they would be confiscated. The rifle the skinheads had is a Valmet M62, a semi-automatic rifle that is a civilian clone of the full auto RK-62 assault rifle; it is also quite possible the Valmet's they had were illegally modified to be fully automatic, which would have seen all of them charged with a class B felony under federal law.
6. The travel agent mentions that the Carribean Island of Montserrat is no longer a hot tourist destination because it is covered in volcanic ash. On July 18, 1995, the island's volcano, Soufrière Hills, entered a period of high volcanic activity that lasted for a little over fifteen years. There was a minor eruption on July 18, then, between March 27 and September 17, 1996, there were two major explosive eruptions (similar in style to the 1980 Mt. Saint Helens eruption) and over a dozen smaller eruptions. The first explosion blanketed the capital city of Plymouth, 6 kilometers (3.7 mi) away, in a thick layer of ash and darkened the sky almost completely. The second large eruption caused a major pyroclastic flow that caused severe damage to the village of Long Ground, near the volcano. The frequent minor eruptions caused regular pyroclastic flows and mudflows; this led to the entire southern island, including Plymouth, to be permanently evacuated. A third large eruption on June 25, 1997 killed nineteen people and destroyed the island's main airport on the northern part of the island. This led to the central part of the island being evacuated and the closing of the island to all tourism. A total of 7,000 people (2/3's of the population) were evacuated from the island, most by the HMS Liverpool (D-92), a Royal Navy Type-42 destroyer. By August 1997, additional eruptions had caused nearly all of the southern part of the island to be buried by pyroclastic flows. The volcano ceased its near constant eruptions in 2010, and its most recent eruption was in 2013. As of 2025, the volcano is still mildly active, but it has gone twelve years without an eruption, and the island is once again seeing tourism.
7. Rosa Arredondo has played four different roles over the course of the series:
   • Episode 6.7 Humiliation (1995) - Nina.
   • Episode 9.10 Hate (1999) - Cecilia (as Rosa Evangelina Arredondo).
   • Episode 12.12 Undercovered (2002) - Mrs. Garcia.
   • Episode 19.18 Promote This! (2009) - Juanita Stratton.
8. Felix Solis has portrayed four different characters throughout the course of the series:
   • Episode 8.4 Harvest (1997) - CSU Scapelli.
   • Episode 9.10 Hate (1999) - Tino.
   • Episode 16.14 Magnet (2006) - Mr. Garcia.
   • Episode 19.17 Anchors Away (2009) - Livan Santana.
9. As a point of clarification, the term "assault rifle" and "assault weapon" is very often misused by those who don't have understanding or experience with how guns function, and the term is intentionally misused by the anti-gun politicians as a fear mongering tactic to scare people. The actual technical definition of a military assault rifle is one capable of burst fire and/or full automatic fire, aka a machine gun. The technical and legal definition of a machine gun is "a firearm capable for firing more than one round with a single trigger movement", this includes burst fire weapons that fire several rounds (usually 2-3) with each trigger pull like the M16A4 & M4, and fully automatic which continuously fire when the trigger is held down like the M16A1 and M4A1. Which is why it is incorrect to refer to rifles like the AR-15, Norinco and Valmet as "military assault rifles", they may have a physical resemblance to their military counterparts, however they are completely different function-wise. They're civilian semi-automatic rifles, which only fire a single round with each trigger pull; they are not military-issue rifles, or machine guns.Their use in crime is severely over exaggerated too. According to the FBI, in the last five years there are over twice as many people each year assaulted and killed with knives (1,170), than with rifles (470), and over ten times as many people are assaulted with handguns (5,270) than rifles; many of which are not legally owned firearms. Although those are but a very tiny fraction (0.000147%) of the 390 million legally owned firearms in the U.S., there's an estimated 200 million legally owned handguns, 110 million legally owned rifles with at least 45 million legally owned rifles being AR-15 or AK-47 style rifles. It's also almost never pointed out that an estimated 2.5 million guns are used for self defense each year, even the most conservative estimates are 70,000. Some estimate it's likely much higher and closer to 5 million, since many defensive gun uses aren't reported because the gun isn't actually fired, the mere displaying of a gun can be enough to prevent an attack. That translates to a statistical average of at least 191 guns used each day for self defense, and possibly as many as 6,850.
10. A Law & Order: Special Victims Unit (1999) episode is also titled Hate (2004).
11. Matte Osian (Raymond Stoller) also played the role of James Buckley in episode 15.24, Locomotion (2005).

Ramparts

1. This episode appears to be based on the following cases/incidents:
   • The 1985 Handschu agreement.
   • The 1997-1998 Rampart scandal which affected the CRASH unit of the Los Angeles Police Department.
   • Suspicions and evidence that Donald DeFreeze was an informant for the LAPD and/or the CIA.
   • The controversial COINTELPRO program.
   • The Mississippi Burning murders.
   • The Weather Underground anti-war movement.
   • The term "agent provocateur".
2. The judge at the hearing is Honorable Lisa Pongracic. In 1992, Saturday Night Live (1975) had sketch titled "Lisa Pongrasic, Very Pregnant Undercover Cop."
3. Guest star Roy Thinnes played D.A. Alfred Wentworth in the series pilot, Everybody's Favorite Bagman (1990) (produced 1988; aired 1990).
4. Lennie suggests trying to start the VW bus after it's been pulled out of the Hudson. It's possible that he was facetiously referring to the 1960s VW brand's reputation for hardiness and reliability.
5. The episode's title "Ramparts" has a double meaning. A rampart is the outer wall of a castle or fortress that is used as a defensive fortification, and it usually has a wide top that allows guards and defenders to walk on top of the wall and use it as both cover & as a vantage point to fend off attackers. It is also a metaphor for how Darryl Grady felt he had to come to the defense of his son's honor. Rampart is also a metaphor for the NYPD's "thin blue wall", which has both positive and negative connotations. It's positive in that police officers consider each other brothers and sisters and have one another's backs, but it can be negative when their loyalty goes too far and protects corrupt officers.The episode title also refers to the Rampart scandal, which was an ongoing event when this episode was written. Rampart is the name of one of the major divisions (equivalent to an NYPD borough) of the Los Angeles Police Department. Between 1997-2002, Rampart Division was the target of a major investigation of police corruption, specifically Rampart's Community Resources Against Street Hoodlums (CRASH) anti-gang unit faced allegations of widespread criminal activity. More than 70 police officers were initially implicated in various forms of misconduct, including police brutality, planting of false evidence, stealing & drug dealing, bank robbery, perjury, and cover-ups. Of the 70 officers implicated, there was sufficient evidence to bring 58 before an internal administrative board, and 24 were found to have committed either criminal or civil wrongdoing, with twelve officers being suspended for various lengths, seven forced into resignation or retirement, and five terminated. Additionally, several officers also faced state and federal criminal charges. LAPD officer David Mack was arrested by the FBI on charges of armed bank robbery after his girlfriend, an assistant manager at a Bank of America branch, confessed to helping him steal $722,000 from the bank; in 1997, Mack was tried and convicted in the United States District Court for the Central District of California and sentenced to 14 years & 3 months in federal prison. He was paroled on on May 14, 2010, but the money he stole was never recovered. Officer Rafael Pérez was arrested on August 25, 1998 after evidence was uncovered that he stole over six pounds of cocaine from the LAPD evidence lockup, worth over $800,000 ($1,583,121 in 2025), and he was tried in Los Angeles County Superior Court on charges of theft and drug trafficking and faced a minimum sentence of 20 years in prison. The case ended with a mistrial. Afterwards, Perez agreed to a plea agreement in exchange for a maximum sentence of 5 years in prison, and he agreed to testify to his knowledge of other police misconduct, which led to 24 officers facing disciplinary actions. As a result of the CRASH unit's planting evidence, perjury, and witness tampering, a total of 106 criminal convictions were overturned by the California Court of Appeals for the Second District and the United States Court of Appeals for the Ninth Circuit. The city of Los Angeles faced 140 civil lawsuits, costing the city $125 million in settlements.
6. The police interview Kenneth Stratton, who was one of the student protesters who had occupied the office of the fictional Kensington University's president's office and mentions smoking a cigar. This was a reference to the real life David Shapiro, who was famously photographed smoking a cigar while occupying the office of the President of Columbia University in 1968.
7. It's mentioned that Bernstine (the victim) was able to get amounts of money that were considered especially large in 1968, especially for someone that was supposed to be unemployed. Carmichael mentions he paid $500 for the VW Bus, bankrolled $800 for the protest supplies, and was paying $1,500 a month in tuition. Adjusting for inflation, $500 in 1968 would be equivalent to $4,634 in 2025, $800 would be equivalent $7,415 in 2025, and $1,500 equivalent $13,903 in 2025. Altogether Bernstine spent $2,800 that month, equal to $25,953 in 2025.
8. Abbie Carmichael mentions the bombing of the World Trade Center. The was broadcast in 1999, before the terrorists attacks on 9/11/2001. She was talking about an earlier event on February 26, 1993, when a van filled with explosives blew up in the parking garage under the North Tower. There was extensive damage, but it failed to collapse the building as the terrorists has hoped. A more successful attempt was made eight and a half years later.
9. Daryl Edwards has portrayed fours different characters over the course of the series:
   • Episode 1.8 Poison Ivy (1990) - Richard.
   • Episode 9.11 Ramparts (1999) - Allan Taylor.
   • Episode 11.1 Endurance (2000) - Nathan Walpole.
   • Episode 15.13 Ain't No Love (2005) - Shawn Foreman.
10. Dan Ziskie has played six different roles over the course of the series:
    • Episode 5.19 Cruel and Unusual (1995) - George Jeffries.
    • Episode 7.6 Double Blind (1996) - Fred Sawyer.
    • Episode 9.11 Ramparts (1999) - Captain Gene Sayres.
    • Episode 11.23 Judge Dread (2001) - State Police Investigator.
    • Episode 14.12 Payback (2004) - Joshua Kramer.
    • Episode 16.12 Family Friend (2006) - Captain Tom Baden.
11. In the marina scene, there is a boat visible with the name Camelot. Besides the episode name, and historical references pointed out above, Camelot was the nickname of the JFK administration, "a time characterized by a hopeful, stylish, and glamorous image likened to the mythical court of King Arthur. The comparison was famously initiated by his widow, Jacqueline Kennedy, shortly after his assassination, as a way to memorialize his legacy and evoke a sense of promise and greatness that was tragically cut short."

Haven

1. The cheating strategy described in this episode is based on a real-life scandal that was exposed in 1997. A California man, George Kobayashi, paid experts to take standardized tests in New York and telephone him with the correct answers. Kobayashi, based in Los Angeles, then inscribed the correct answers on pencils which were distributed to his students. Because the tests were administered at the same local time in each location, the three hour timezone difference between the coasts allowed the scheme to work.In 1998, Kobayashi was sentenced to four years imprisonment after being convicted of organizing the scheme.
2. Ruben Santiago-Hudson has played four different roles over the course of the series:
   • Episode 1.11 Out of the Half-Light (1990) - Mr. Gaines.
   • Episode 5.6 Competence (1994) - Detective Brian Keene.
   • Episode 9.12 Haven (1999) - Attorney Winters.
   • Episode 11.18 White Lie (2001) - Attorney Winter.
   • Episode 14.6 Identity (2003) - Dr. Paul Jackson.
   • Episode 18.14 Burn Card (2008) - Attorney Winters.
3. ADA Carmichael tells the student selling answers to final exams that he could potentially face criminal charges. In most instances, cheating and/or facilitating the cheating of college and university exams is not a criminal act, but rather a violation of the academic policies of the school that can result in penalties such as being held back a year, forfeiture of scholarships, suspension, or expulsion; if the student cheating was on a scholarship they not only lose it, but also are often required to reimburse the foundation or institution that funded the scholarship. However in rare and extreme circumstances, providing the answers to exams can be a criminal act. If the study and exam material for a test was created by a third-party, such as a publishing company, and is being used by the school under a copyright agreement, any student distributing, or reprinting all or part of the material without authorization, would be in violation of United States copyright laws. Specifically they would be guilty of criminal copyright infringement, a violation of The Copyright Act of 1976 and a federal offense under 17 U.S.C. § 506, Subsection 1, Paragraphs A-C: each fraudulently distributed copy of a document is at minimum a class A violation with a fine of up to $2,500; if said document has a value over $1,000, and more than one copy was distributed within a 180-day period, it is a class C misdemeanor punishable by a fine of up to $5,000 and/or a sentence of 5-30 days in jail; 10 or more copies distributed within a 180-day period is a class E felony punishable by a maximum fine of $250,000 and/or a sentence of up to 5 years in prison. Additionally if someone was the recipient of a scholarship or grant funded by the state or federal government, cheating on exams to make a profit could result in being prosecuted for fraud. If a student pays a teacher, or an employee of of the exam's publisher, for answers they could also face bribery charges. Or if they use threats or intimidation to either obtain the answers, or to discourage someone from turning them in, they could face charges like criminal coercion, extortion, and menacing.
4. Sean Cullen has played three different characters over the course of the series:
   • Episode 9.12 Haven (1999) - Professor Davis Mills.
   • Episode 14.7 Floater (2003) - Gene Marchetti.
   • Episode 18.13 Angelgrove (2008) - Matthew Lortell.

Hunters

1. The lawyer for the bail bond company files a writ of habeas corpus, claiming Max Sheridan has been unlawfully imprisoned. McCoy argues before the judge that the bounty hunters' taking Mr. Sheridan back to Atlanta to stand trial for payment of their bounty is akin to a motion of replevin. Replevin is a lawsuit--pending a final determination by a court of law--that enables a person to recover personal property taken wrongfully or unlawfully and to receive compensation for resulting losses. In other words, the bail bond company is treating their client like he's property instead of a human being and is thus abusing the right of habeas corpus to maneuver around extradition laws. Extradition law states that New York County should prosecute Mr. Sheridan first because he committed more serious crime there than in Atlanta: Sheridan is facing three counts of second-degree murder in New York County, whereas in Atlanta he's only facing a charge of grand larceny.
2. This episode appears to be based on the 1997 murders of Chris Foote and Spring Wright.
3. As of 2022, 28 states require bounty hunters to either be licensed by the state government, state police, or registered with & issued a permit by the sheriff's department in the county their company does business in, and/or require training & education: Alabama, Alaska, Arizona, California, Connecticut, Delaware, Florida, Georgia, Indiana, Iowa, Louisiana, Mississippi, Missouri, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, Ohio, Oklahoma, South Carolina, South Dakota, Utah, Virginia, Washington, and West Virginia. Four states prohibit bounty hunting altogether, and instead have a special fugitive recovery unit in either their state police, or county sheriff departments: Illinois, Kentucky, Oregon, and Wisconsin.18 states do not require licensing or specific training and education: Colorado, Hawaii, Idaho, Kansas, Maine, Maryland, Massachusetts, Michigan, Minnesota, Montana, North Dakota, Pennsylvania, Rhode Island, Tennessee, Texas, Vermont, Wyoming and the District of Columbia (Washington D.C.).
4. Stephen DeRosa (Al Festov) also played the role of Stan Loomis in Episode 14.20, Everybody Loves Raimondo's (2004).
5. The plot of this episode is similar to a two part episode in season seven of Law & Order's sister series Homicide: Life on the Street (1993), and featured a soon-to-be main character in the L&O franchise. The episodes Wanted Dead or Alive: Part 1 (1998) & Wanted Dead or Alive: Part 2 (1998), are about three bounty hunters who are accused of being overzealous and shooting a murder suspect who was bonded out by their company on a previous robbery charge, and jumped bail. Future Law & Order: Special Victims Unit (1999) & Law & Order: Organized Crime (2021) star Christopher Meloni guest starred in the two episodes as Dennis Knoll, the supervisor of the bounty hunters. Meloni's performance in these two episodes, and his performance as Chris Keller in Oz (1997), is primarily what led to him being chosen for the role of Detective Elliot Stabler.
6. Merwin Goldsmith plays Judge Ian Feist in this and 10 other episodes. He previously played the part of Trial Judge Gollub in Episode 1.17, Mushrooms (1991).
7. Michael Hobbs has played four different roles over the course of the series:
   • Episode 16.4 Age of Innocence (2005) - Doctor
   • Episode 11.18 White Lie (2001) - Pat Conners
   • Episode 9.13 Hunters (1999) - Spellman
   • Episode 7.1 Causa Mortis (1996) - Sergeant
8. Two of the actors that appeared in the Police Squad! (1982) television series, Alan North and William Duell, have cameo roles in this episode.
9. Jesse Doran and Jerry Orbach were both in Toy Soldiers (1991).

Sideshow

1. Initially broadcast two months after President Clinton's acquittal, after being impeached, over charges arising out of the Monica Lewinsky scandal. Before sightseers discover the dead body by Castle Clinton in New York, a woman sightseer says: "There's the restroom. They should name that after the President." In this episode, the grand jury is presided over by Independent Counsel William Dell, who appears to be out of control, leaking testimony to the press and taking a strong interest in people's personal lives.
2. Sam Waterston's character, Jack McCoy's full name is John James McCoy. He gives his full name in the episode Sideshow in order to have it placed on a grand jury subpoena.
3. Independent Counsel William Dell asks McCoy whether Kincaid was "another one of your lovers at the D. A.'s office" at the time of her death. McCoy does not reply. Although several earlier episodes of "Law and Order" had strongly hinted that Kincaid and McCoy were lovers, this is the first time that such a relationship is explicitly mentioned or depicted.
4. William Dell is based on Ken Starr, the leader of the independent council that investigated allegations of sexual harassment and sexual assault in the White House - specifically harassment of interns by staff members and sexual assault committed by President Bill Clinton, though Starr's investigation went off on a tangent when he started investigating the President's involvement with Monica Lewinsky. Like with Mr. Dell in this episode, Mr. Starr's investigation wasn't really focused on investigating criminal wrongdoing but rather the sexual habits and orientation of certain government officials. Mr. Starr was an extremely conservative, Republican, Christian who believed that homosexuality and sexual relations for any reason other than procreation were wrong. He was eventually brought up on charges of official misconduct for leaking details of grand jury testimony in an effort to ruin the careers of certain government officials whose sexual habits and/or orientation he found immoral, including President Clinton. His final report's relevance and purpose were also heavily criticized for making controversial accusations about exactly what Clinton did. The report claimed "the details are crucial to an informed evaluation of the testimony, the credibility of witnesses, and the reliability of other evidence. Many of the details reveal highly personal information; many are sexually explicit. This is unfortunate, but it is essential." This accusation was proven to be false. Because Starr regularly leaked tidbits to press about the lurid, lengthy, sexual details that were mentioned in his report, he was criticized for using the scandal as a political maneuver and was charged for violating legal ethics by presenting information irrelevant to an investigation as evidence of legal wrongdoing. Also, it is unclear whether Starr had the legal authority to ask Clinton questions about his sexual relationship with Lewinsky, as the OIC was convened solely to investigate allegations made by a couple of White House interns that they were sexually harassed by White House staff and sexually assaulted by President Clinton. Questioning about a sexual relationship void of assault appears to be both irrelevant under the Federal Rules of Evidence (FRE) as a whole and under Rule 413, which allows questioning about separate allegations of sexual assault (which was never asserted about Lewinsky's relationship with Clinton). In the end, the accusations that President Clinton sexually assaulted interns was proven to be false.
5. This episode is found on disc 3 of the Season 9 DVD box set of "L&O." Originally when broadcast on TV, the plot of this episode was concluded on Sideshow (1999). Yet, while that "Homicide" episode in included in the Season 9 "L&O" DVD box set for continuity, for some reason the "Homicide" conclusion episode is not included on the same disk as the "L&O" prequel episode. The "Homicide" concluding episode is included as a bonus feature on disc 1 of the "L&O" DVD box set.
6. During McCoy's grand jury appearance before Special Counsel William Dell, Dell brings up events from several past episodes as follows:
   • Under the Influence (1998) - McCoy withholds evidence against a drunk driver accused of killing a mother and son.
   • Trophy (1996) - McCoy's former assistant and lover Diane Hawthorne illegally withholds evidence that leads to a wrongful conviction in a murder case.
   • Corruption (1996) - Briscoe is brought before the Hellman Commission in a drug trial.
   • Damaged (1998) - Briscoe's daughter is murdered after testifying against her drug dealer boyfriend
   • Aftershock (1996) - Claire Kincaid is killed while driving a drunk Briscoe home.
7. McCoy is called before William Dell, who he says is the Independent Council, which is an independent lawyer appointed by the Attorney General to investigate and prosecute criminal violations by high-ranking government officials. An independent council is a private practice attorney who is not a federal government employee, and they are appointed to avoid a conflict of interest that would otherwise be present if the criminal violations were investigated by an Assistant U.S. Attorney. For example, if the government official under suspicion is a fellow member of the Attorney General's office, a federal judge, or someone who is personally associated with the Attorney General.
8. Castle Clinton (also known as Fort Clinton and Castle Garden) is a restored fort in Battery Park. Built from 1808 to 1811, it was the first American immigration station, predating Ellis Island. More than 7.5 million people arrived in the United States at Fort Clinton between 1855 and 1890. It was originally called the West Battery and was equipped with naval cannons to protect New York City from naval attacks, but it never saw use in war. In 1815, it was renamed to Fort Clinton in honor of DeWitt Clinton, who served as the 47th Mayor of New York City from 1803-1807, 49th Mayor from 1808-1810, and the 51st Mayor from 1811-1815. Clinton also served as the Acting Lieutenant Governor of New York from 1811-1813 and the 6th Governor of New York from 1825-1828. Clinton also ran against the incumbent President James Madison in the 1812 Presidential Election, winning the Federalist Party nomination. He also had support from some of the Democratic-Republican Party, which Madison was the candidate for, though Madison won and was re-elected by a narrow margin. It served as a military fort until 1824 when the city converted it into a 6,000-seat entertainment venue known as Castle Garden, which operated until 1855.
9. Munch mentions the Red Mass, which is a popular target for conspiracy theorists, leading to a lot of misconceptions about it. Munch says it is held the Sunday before the Supreme Court holds its first session, and this part is true; he next claims it is a secret Mass held just for the Supreme Court where they conspire with the Church, and this part is total fiction. It is not secret, and any and all legal professionals are welcome. The Red Mass is a Catholic Mass held annually for all members of the legal profession, regardless of religious affiliation and is attended by: judges, lawyers, law school professors, law students, and government officials, marking the opening of the judicial year. The religious service requests guidance from the Holy Spirit for all who seek justice, and it offers the legal community an opportunity to reflect on the power and responsibility of all in the legal profession. It gets its name from the red vestments that are traditionally worn by cardinals and bishops in symbolism of the Holy Spirit; during the Red Mass, red vestments are also worn by priests and sometimes Supreme Court Justices.The Red Mass was around long before the United States and originated in France; it was first held at the Cathedral of Paris in 1245 and was originally held in honor of Saint Ives, the Patron Saint of Lawyers. From there, the tradition spread to other nations in Europe. The Red Mass was first held in England in 1310, and it was attended at the opening of each term of Court by all members of the Bench and Bar; since its construction in 1910, the Red Mass has been held annually at Westminster Cathedral. The first Red Mass was celebrated in the United States in 1877 at Saints Peter and Paul Church in Detroit, Michigan and was held regularly starting in 1912. It is also held at churches near major law schools across the country. The best known Red Mass is the one held at the Cathedral of St. Matthew the Apostle in Washington D.C.; since 1953, it has been held on the Sunday before the first Monday in October (the Supreme Court convenes on the first Monday in October). It is usually attended by some of the United States Supreme Court Justices (but not all choose to attend), State Supreme Court Justices (usually from the states surrounding D.C.), federal & state Appellate Court judges, federal & state District Court judges, the Attorney General & local District Attorneys, private practice attorneys, members of the diplomatic corps, members of Congress & the Cabinet and sometimes the President & Vice President. The Red Mass is held in other countries as well, including Australia, Canada, Ireland, Philippines, Scotland, and most nations with a large Catholic population.
10. Interestingly, being that this is a cross over with Homicide: Life on the Street (1993), John Dossett had already appeared in Homocide as a different character in The Last of the Watermen (1994) as an old boyfriend of Kay Howard.
11. Kevin Elden has played five different roles over the course of the series:
    • Episode 14.8 Embedded (2003) - Bernie
    • Episode 11.21 Brother's Keeper (2001) - Payton
    • Episode 10.1 Gunshow (1999) - Dan Hayala
    • Episode 9.14 Sideshow (1999) - CSU Detective Kett
    • Episode 9.1 Cherished (1998) - Oscar Castellano
12. One of the characters refers to Senator Romney, nearly 30 years before Mitt Romney was elected the junior senator from Utah.
13. It's mentioned the victim had a security clearance because she worked as a Deputy Director of the Social Security Administration. The United States government has seven different types of security clearance levels: Public Trust clearance, which is considered the lowest level, where a basic background check is conducted to verify the employee's suitability for handling sensitive, non-classified information, like the kind of information Social Security employees have access to. Confidential clearance is the lowest needed to access classified information, typically taking a few weeks to a month to obtain. It provides access to information that can cause damage to national security if it is disclosed without authorization. It must be re-investigated for continued eligibility every 15 years. Additionally, confidential clearance requires a National Agency Check, Local Agency Check, and Credit Check (NACLC), and this involves the FBI searching all federal criminal databases, while a contracted private investigator does a credit check and a background check of local law enforcement agencies to see if the applicant has ever been arrested or convicted of any state level crimes, usually arrest/conviction for minor crimes isn't a disqualification. Secret clearance, requires a few months to a year of investigation to obtain, depending on the individual's background, and it grants access to information that can cause serious damage to national security if disclosed without authorization. Must be re-investigated for continued eligibility every 10 years and requires NACLC and a Credit investigation. Any previous criminal record is an automatic disqualification, and a more detailed investigation of the applicant's credit history is done; if the applicant has filed or bankruptcy in the past or has a poor credit history, they are usually denied. Top Secret clearance is one of the most restrictive, often taking 6 to 18 months of investigation to obtain, and it grants access to information that can cause grave damage to national security if disclosed without authorization. Must be re-investigated for continued eligibility every five years. Typically granted after a Single Scope Background Investigation (SSBI) for data related to counterterrorism, counterintelligence, and other extremely sensitive information; this is in addition to the NACLC investigation that's done for lower levels. The SSBI is a deep investigation into the applicant's background done by the FBI, CIA & NSA and includes interviews with the applicant's family, friends, and coworkers about the applicants history to see if they are trustworthy. The applicant's social background is investigated as well, and any close personal ties to people in certain groups or countries that are considered unfriendly to the U.S., like China, Russia, North Korea and any domestic or foreign groups on terrorism watchlists will often be a disqualification. The applicant must also submit to several interviews done with a polygraph. Top Secret - Sensitive Compartmented Information (aka Above Top Secret & Need-to-Know Only) is the second most restrictive type of clearance, and it grants access to information that is considered so critically sensitive that unauthorized disclosure would be devastating to national security and usually involves intelligence information. This information is physically protected, and it can only be stored and accessed in special, highly secure areas called a SCIF (Secure Compartmented Information Facility). Access to Top Secret/SCI is compartmentalized, meaning unlike information in the other clearance levels - it is only granted to people working in a certain area that have a need to know; so, for example, someone in Naval Intelligence with Top Secret/SCI clearance is only going to be permitted access to SCI data pertaining to Naval Intelligence; they don't have access to SCI data from any other intelligence agency. SCI clearance is typically granted only after rigorous SSBI and adjudication processes, which are re-investigated every three years. Special Access Programs are the absolute highest type of clearance and requires the most restrictive access protocols involving highly sensitive projects for the Department of Defense that are separate from compartmented intelligence information. Special Access Programs usually involve information pertaining to military technology; for example, information about the stealth technology used on B2 and B21 bombers & Zumwalt-class guided missile destroyers or the schematics for the arming, control guidance, launch, and safety systems for strategic nuclear weapons, like ICBM's & SLBM's, are contained within Special Access Programs. This clearance level is granted to very few individuals, and not even the President of the United States has access to information in these programs.

Disciple

1. This episode appears to be based on the 1998 Charity Miranda case. Charity's mother, Vivian, and a classmate, Serena Martin, engaged her in a two-hour exorcism because her mother believed that Charity had a demon inside of her. Charity died during the exorcism process, and to cover her death, her mother placed her in a plastic bag, leaving her at the bottom of the stairs.
2. Rosa Halasy says, "I went to Catholic school all my life. Then to a convent at Monticello." She pronounces Monticello like "Montasello", which is how the locals do pronounce it. Per the Village of Monticello's "Fun Facts": "The village was named after the residence of Thomas Jefferson, but is pronounced as 'mon-tah-sell-oh'."
3. Bishop Ribot mentions that the "Rituale Romanum is never performed by a novice". "Rituale Romanum" is Latin for "Roman Ritual", it is one of the official liturgical books of the Roman Catholic Church and contains all of the rituals and services that a priest or deacon may perform. This includes things like the ritual prayers and incantations for baptisms, blessings, funerals, and weddings. It also contains the ritual to correctly perform an exorcism, and as the Bishop states it is not to be performed by novices. An exorcism can only be performed by ordained priests, and only with the blessing of the Archbishop in charge of the Archdiocese where the exorcism is to be performed, and is done by a team specially trained priests from one of the Vatican's secret orders. The Archbishop will only grant their blessing after a thorough investigation has been performed, and the Archbishop has consulted with the Pope and obtained his blessing and permission.
4. Lennie says, "Maybe we can find someone in this dump who knows more than Miss Congeniality here." Benjamin Bratt will go on to play Eric Matthews in Miss Congeniality (2000).
5. When Carmichael asks McCoy if he really believes in Satan the Devil, McCoy replies "I've been prosecuting rapists and murderers for 25 years, I've seen things I can't explain as anything other than evil, such as a man raping a 10 year-old girl, spraying a can of insecticide in her mouth, and leaving her for dead". He is referring to the season 8 finale Monster (1998) when Briscoe and Curtis investigated the rape of 10 year-old Malika Richardson, who was found in a coma in the basement of her apartment, the man that raped her sprayed an entire 10 gallon drum of bug spray into her mouth, leaving the girl brain-dead.
6. ADA Carmichael says that Kyra Grayson was described as being "hell on wheels". This phrase originated in 1869 to describe the immoral and lawless mobile shanty towns that accompanied the army of Union Pacific Railroad Company (UPRC) workers as they constructed the first transcontinental railroad in 1860's North America. In modern times the phrase has come to refer to a person who does nothing but cause trouble, and cares only about themselves.The Union Pacific line began in Council Bluffs, Iowa in 1863 and worked its way west, and the Central Pacific Railroad Company of California (CPRC) started its line in Sacramento, California and worked its way east, until the two lines met in Promontory Summit, Utah Territory on May 10, 1869. At 1,085 miles long, the Union Pacific's rail line was the longest (the CPRC's was only 680 miles), in addition to being almost twice as long, it also passed through the dangerous frontier territory of the Indian Nations, and by far required the most number of men, both workers and guards to protect the works from attacks by both outlaws and Indians. To support these workers, a makeshift town made from canvas tents followed the line as it progressed, this town included not only practical things like general stores but also gambling houses, dance halls, saloons, and brothels. Since much of the Union Pacific's work was done in remote wilderness, outside the jurisdiction of most forms of law enforcement, only the United States Marshals Service had jurisdiction in the Indian Nations, these railroad towns quickly developed a reputation of being dangerous, lawless dens of sin and iniquity, where assault, rape and murder were daily occurrences. Which earned these railroad shanty towns the nickname of Hell on Wheels. The lawlessness and violence got so bad, the UPRC was forced to hire lawmen and gunslingers as private law enforcement, and in the final years the government was forced to send a platoon of the U.S. Army Cavalry to provide security; which is the basis for the series Hell on Wheels (2011).
7. Bill Camp (Barney Rade) also played the role of Denny Rogis in episode 14.20 Everybody Loves Raimondo's (2004).

Harm

1. This episode appears to be based on the 1997 Lisa Smart medical malpractice case in New York City.
2. Christina Rouner has played three different roles over the course of the series:
   • Episode 9.16 Harm (1999) - Mrs. Atkins.
   • Episode 13.13 Absentia (2003) - Anne-Marie Gautreaux.
   • Episode 18.8 Illegal (2008) - Attorney Sanders.
   • Episode 20.8 Doped (2009) - Attorney Sander.
3. Stephen Bogardus has played three different roles over the course of the series:
   • Episode 9.16 Harm (1999) - Dr. Peter Michaels.
   • Episode 12.19 Slaughter (2002) - Jim Dittmar.
   • Episode 20.8 Doped (2009) - Austin.
4. Brenda Pressley (Danielle Lindsey) also played the role of ADA Shannon Hayes in Episode 11.12, Teenage Wasteland (2001).
5. Larry Pine (Dr. Jacob Weiss) previously played the role of Edward St. John in Episode 5.9, Scoundrels (1994).
6. Sam Freed played three different roles over the course of the series:
   • Episode 2.14 Blood Is Thicker... (1992) - Kent Meeker.
   • Episode 9.16 Harm (1999) - Dr. Bill Rudnick.
   • Episode 16.20 Kingmaker (2006) - Tom Baker.
7. Michael Gaston has played five different roles over the course of the series:
   • Episode 4.22 Old Friends (1994) - Wheeler.
   • Episode 7.9 Entrapment (1997) - Ron Fletcher.
   • Episode 9.16 Harm (1999) - Mr. Delany.
   • Episode 11.18 White Lie (2001) - Major Jim Wyman.
   • Episode 19.15 Bailout (2009) - Pete Gardner.
8. Character actor Charlie Dell plays one of the jurors.

Shield

1. ADA Carmichael mentions that Officer Hastings worked with Officer Cass on the "Trick or Treat Squad". There is no actual unit or squad with this name, it is used as an informal nickname for the officers who volunteer to work on Halloween night. Since that night has a lot of children out trick or treating, and a lot more people in general on the streets than normal, the NYPD typically has twice as many officers on duty on October 31 then they do on a typical night, with many of them on foot patrol through neighborhoods. Officers volunteering for this assignment are usually given overtime pay for it. This is also commonly done by most city police departments across the nation.
2. Actress Jenny Bacon (Officer Marissa Hastings) has also appeared in Law & Order: Criminal Intent (2001) and twice in Law & Order: Special Victims Unit (1999).
3. Skipp Sudduth has played three different roles over the course of the series:
   • Episode 5.17 Act of God (1995) - Henry 'Hank' Chappel.
   • Episode 7.5 Corruption (1996) - I.A.B. Detective.
   • Episode 9.17 Shield (1999) - Officer Cass.
4. Madison Arnold has played five different roles over the course of the series:
   • Episode 1.13 A Death in the Family (1991) - Bridges.
   • Episode 6.23 Aftershock (1996) - Leonard Jensen.
   • Episode 9.17 Shield (1999) - Mr. Pelham.
   • Episode 10.11 Collision (2000) - Patrick Clarke.
   • Episode 15.14 Fluency (2005) - Reimer.
   • Episode 19.10 Pledge (2009) - Saul Lasky.

Juvenile

1. Matt Bennett and Marsha Dietlein, who play brother and sister 'Nicole Hampton' and 'Andrew Hampton' in this episode, eventually married each other two years after the airing of this episode.
2. This episode appears to be based on the Stephen Glass fabrication scandal.
3. Frank Vincent's character (Franchetta) was recently paroled after serving 20 years in prison. He also plays a character in the television series The Sopranos (1999) who was released after serving 20 years in prison.
4. On October 1, 2018 the state of New York passed the Raise the Age (RTA) Act, which raised the minimum age for criminal responsibility for nearly all crimes to 18. The RTA also created new, or altered existing, offender categories: Juvenile Delinquent (JD), Youthful Offender (YO), and Adolescent Offender (AO). Under the RTA, a Juvenile Delinquent is a minor between the age of 7-18 who has committed an offense that would be considered a crime if committed by an adult, minors aged 16 & 17 who commit a misdemeanor (except for traffic law violations, in which case they are treated as adults) are tried as a JD, JD's are tried in Family Court and are not sent to jail, instead the court decides if they need supervision, treatment or placement through the local department of social services, and JD's do not have a criminal record; minors under the age of 13 are not charged with misdemeanors, and minors under 7 aren't charged with felonies. The RTA changed the definition of Juvenile Offender (JO) to a minor aged 13, 14, or 15 who commits a serious violent felony including murder in the second degree, any first degree violent felony sex offense, first degree arson, first degree kidnapping, and first & second degree robbery; JO's are tried in the Youth Part of the Supreme Court or County Court and receive less severe sentences than adults, and have a criminal record, unless the judge grants them a YO status. Youthful Offender status can be granted, at a judge's discretion, to minors between 14-19 who have no prior felony convictions, and have never been granted YO status before; a minor convicted as a YO has their record sealed, causing them to not have a criminal record. Finally, Adolescent Offenders are minors aged 16 or 17 that commit a felony; if the crime is a non-violent felony the judge will remand the case to Family Court where they will be tried as a JD, unless the District Attorney files a request for them to be tried as an AO, in which case they're tried in the Youth Part of the Supreme or County Court; if the crime is a violent felony then they will be tried as an AO and treated as an adult, meaning they will have a felony criminal record, although they will be sentenced less severely. Adults who were convicted as Juvenile Offenders or Adolescent Offenders (except for sexually motivated violent felonies), can petition the court they were convicted in to have their criminal record expunged, if they have had a clean criminal record for a minimum of 10 years after they successfully finished their jail and/or probation sentence.
5. Julian Gamble has played four different roles over the course of the series:
   • Episode 6.2 Rebels (1995) - Councilman Jack Rabe.
   • Episode 7.2 I.D. (1996) - Judge P. 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.

Tabula Rasa

1. In the opening Jerry Orbach as Detective Lennie Briscoe refers to the transit worker urging him to release the train as "Benito". This is a sarcastic reference to Benito Mussolini, whose fascist regime in Italy was reputed to have kept the trains running on time.
2. As is often the case in Law & Order, the Path train stands in for the New York City Subway.
3. "Tabula Rasa" is a Latin phrase which translates to "blank slate." It is mainly used as the name for a particular type of philosophy that believes that at the start of life everyone is a blank slate, in other words that everyone is born without any built-in mental knowledge (instinct) and that all knowledge a person possesses is acquired through experience or perception.
4. This episode appears to be based on the Rachael and Lisa Martin kidnapping case.
5. When Professor Rothenberg is trying to argue that what Nick Taska/Bill Fallon did doesn't constitute kidnapping in the first degree, he starts to quote New York Penal Code, Article 135, Section 30, but the judge cuts him off saying that she is familiar with that statute. New York Penal Code 135.30 states: "In any prosecution for kidnapping, it is an affirmative defense that (a) the defendant was a relative of the person abducted, and (b) his sole purpose was to assume control of such person".Which means when a parent abducts their child, or when any person abducts someone that is related by whole or half blood, and they do so without the intent to hold them for ransom, harm them physically or sexually, or further another criminal act, they cannot be charged with kidnapping in the first degree (a class A-I felony with a sentence of 15 years to life in prison), or kidnapping in the second degree (a class B felony with a sentence of 5-25 years). If the person abducted was a child of their relation under the age of 16, and the child was abducted in violation of a custody ruling, they could only be charged with: custodial interference in the second degree (a class A misdemeanor with a max sentence of up 1 year in jail), or custodial interference in the first degree if the child was placed at serious risk of physical injury (a class E felony with a max sentence of 1-4 years). If the person abducted wasn't a child, then they would be charged with either unlawful imprisonment in the second degree (class A misdemeanor), or unlawful imprisonment in the first degree (class E felony) if they were placed in serious risk of injury.
6. Grimaldi's Pizza in Brooklyn, where the suspect ate, establishing himself as a seasoned New Yorker, is a real place, still in business in Brooklyn since 1990.
7. Sylvia Fallon tells McCoy and Carmichael that she and her daughter have to leave, because her husband told them to meet him at exactly 4:00 PM. Carmichael replies "So you're late, and what, he starts rearranging the teacups". She is referring to the movie Sleeping with the Enemy (1991), in it Julia Roberts plays Laura, a woman who fakes her death to escape her abusive, and controlling husband who obsessively has to control everything, right down to the way the cups are arraigned in the cupboard, if they aren't arranged exactly by size and color he would beat her. Several years after starting a new life, her ex-husband manages to track her down, but instead of confronting her right away he decides to torment her psychologically first by breaking into her house at night, and rearranging her teacups, and the soup cans in the pantry, in the exact manner he demanded she arrange them when they lived together; this was his way of telling Laura he had found her, and that she would never be free of him.
8. Guest star Jay O. Sanders would later appear in the L&O Universe as Captain Joseph Hannah in the final season of "Law & Order: Criminal Intent".
9. Nick Taska (a.k.a. William Fallon) kidnapped his daughters Susan and Cynthia on March 8, 1984.
10. Professor Rothenburg was definitely right about one thing when it comes to the misconceptions about being charged with DWI. It doesn't matter what kind of substance a person is under the influence of, whether it be: alcohol, illegal drugs like heroin, legal drugs like marijuana, prescription drugs like opioid analgesics (codeine, hydrocodone, oxycodone), anxiety medications like benzodiazepines (Ativan, Valium, Xanax), or antidepressants (Prozac, Zoloft). A person who drives while under the influence of any substance that impairs a person's judgment, reaction time, or hand-eye coordination, can result in being charged with driving while intoxicated.Since the wide-spread legalization of marijuana, there has been a large misconception about the effects marijuana can have a person's ability to drive safely, and many didn't realize it was illegal to drive under the influence of cannabis. People who only use cannabis occasionally are especially vulnerable to its impairing effects. As of 2025, 40 states have legalized the medicinal use of marijuana, and 24 states have legalized it for recreational use. In all 50 states, a person can be cited for DWI if they appear to be impaired and test positive for cannabis. Between 2008 - 2019, the number of people charged with driving under the influence of drugs increased by 27%, while the number of people driving under the influence of alcohol decreased by 32%. A study done in 2020 by the CDC on autopsies of people killed in car crashes showed that 40.2% of fatally injured drivers tested positive for alcohol, and 31.8% tested positive for drugs, and of the people who tested positive for drugs, 79% tested positive for cannabinoids. This has led to a number of states passing DWI laws that specifically apply to cannabis. Five states: Illinois, Montana, Nevada, Ohio, and Washington have implemented per se laws, setting a specific legal limit for THC levels in the blood while driving, which vary from 2 ng/mL to 5 ng/mL. Twelve states have passed zero tolerance laws, making it illegal to drive with any measurable amount of THC or its metabolites in one's system: Arizona, Delaware, Georgia, Indiana, Iowa, Michigan, Oklahoma, Pennsylvania, Rhode Island, South Dakota, Utah, and Wisconsin.
11. Larry Gregory has played six different roles over the course of the series:
    • Episode 4.6 Pride and Joy (1993) - Novogrod (as Larry S. Gregory).
    • Episode 6.19 Blood Libel (1996) - First Uniform Policeman (as Larry S. Gregory).
    • Episode 9.19 Tabula Rasa (1999) - Court Officer (as Larry S. Gregory)
    • Episode 10.2 Killerz (1999) - Stevens (as Larry S. Gregory).
    • Episode 12.15 Access Nation (2002) - Uniform Cop #2 (as Larry S. Gregory).
    • Episode 14.12 Payback (2004) - Guard.
12. Actor Gene Dynarski can be seen sitting behind Jay O. Sanders in the courtroom.
13. The reason for Eleanor Taska and Marian Hollis' falling out is never clarified. But one can only assume that it has to do with Nick Taska.

Empire

1. At the time this episode was filmed and originally shown, Benjamin Bratt and Julia Roberts were a couple in real life.
2. The plot is centered around a plan to finance a new stadium in Manhattan for the New York Giants football team. In 2004, five years after this episode first aired, proposals for a publicly-financed "West Side Stadium" for the rival New York Jets football team were pushed by the Jets ownership and state governor George Pataki. The proposed stadium would have formed the centerpiece of New York's bid for the 2012 Summer Olympics. The project failed amid opposition from local residents, businesses and politicians.
3. This episode appears to be based on the arguments between real-estate developer Donald Trump, Mayor Rudy Giuliani, and the New York Yankees owner George M. Steinbrenner III over a new sports stadium.
4. This is 200th episode of the series.
5. This episode has been aired on Sky Italy as a standalone TV movie--with the title "Corruption Empire - Nella morsa del potere"--probably because of Julia Roberts' participation as guest star.
6. Edward Herrmann has played three different characters over the course of the series:
   • Episode 5.12 Progeny (1995) - Drew Seely.
   • Episode 9.20 Empire (1999) - Mr. Mosbeck.
   • Episode 19.17 Anchors Away (2009) - Frederic Matson.
7. This episode is the third time--and third television series--that Gerald Anthony has been cast as a character named Mario. He previously was Marco in One Life to Live (1968) and subsequently reprised the role in General Hospital (1963).Addendum: SMH...this shouldn't need to be pointed out, but "Mario" and "Marco" are two completely different names, and "Mario" is not a coordinate name for "Marco" the way "Marc", Marcus", "Mark" or "Marko" is.

Ambitious

1. A bail surety hearing, also known as a bail sufficiency hearing, is a way for an ADA to ensure that the funds being put up for bail are not illicit proceeds from criminal activity. If other parties are posting bail on the defendant's behalf, the hearing also helps ensure that the third parties are not being threatened or extorted in any way. Once bail has been posted, the DA's office has 72 hours to investigate the funds used and request a surety hearing to contest the legitimacy of the bail funds.
2. Mark Linn-Baker and Joe Piscopo, who play business partners, have the same birthday.
3. This episode appears to be based on the John Gotti Jr. case.
4. Actress Jennifer Van Dyck (Morgana Palmer) once again continues the tradition of the same actor playing multiple characters throughout the Law & Order universe. She has played a total of nine different characters in six episodes of Law & Order (1990), three episodes of Law & Order: Special Victims Unit (1999), and one episode of Law & Order: Criminal Intent (2001).
5. Jennifer Van Dyck has played five different characters over the course of the series:
   • Episode 1.21 Sonata for Solo Organ (1991) - Joanna Woodleigh.
   • Episode 4.16 Big Bang (1994) - Shelly Conners.
   • Episode 7.6 Double Blind (1996) - Jill Perry.
   • Episode 16.19 Positive (2006) - Dr. Elaine Clemens.
   • Episode 9.21 Ambitious (1999) - Defense Attorney Attorney Morgana Palmer.
   • Episode 12.14 Missing (2002) - Defense Attorney Morgana Palmer.

Admissions

1. Medroxyprogesterone acetate (Depo-Provera) is a synthetic form of the female sex hormone progesterone. It is mainly used as a form of birth control for women. However, it is also used in men as a form of chemical castration: it reduces a male's sex drive by inhibiting testosterone production. It is used to treat male hyper-sexuality or to control inappropriate or unwanted sexual behavior in those with paraphilias (intense sexual arousal to atypical objects, situations, or persons) such as pedophilia. The effectiveness of Depo-Provera for treating sex offenders is controversial: a number of studies indicate that its effectiveness at controlling the urges experienced by sexual offenders is minimal at best. For example, the urges experienced by rapists have much more to do with power and control than sex, which is why suppressing sexual desire does little to deter rapists.
2. This episode appears to be based on the 1997 murder of 7-year-old Sherrice Iverson committed by Jeremy Strohmeyer.
3. When Skoda is discussing how the murderer covered the victim's face for modesty, Briscoe says "like that carjacking a couple of years ago." He is referring to episode 7.1 Causa Mortis, when a carjacker killed a woman before taking her car.
4. John Cunningham has played five different characters over the course of the series:
   • Episode 2.11 His Hour Upon the Stage (1991) - Cobb.
   • Episode 3.18 Animal Instinct (1993) - Donald Walsh.
   • Episode 5.2 Coma (1994) - Max Weston.
   • Episode 7.14 Working Mom (1997) - Daniel Metzler.
   • Episode 9.7 Venom (1998) - Daniel Metzler.
   • Episode 9.22 Admissions (1999) - Mr. Crowley.
   • Episode 18.4 Bottomless (2008) - Daniel Metzler.
   • Episode 12.12 Undercovered (2002) - Daniel Metzler.
5. This series, in addition to often re-casting previously hired actors to play different characters, often recycled surnames for guest characters who were unrelated to their previous namesakes ("Russo", "Harlan", and "Maslin", to cite just three examples). This episode features possibly the most bizarre instance, in that the murder victim's name is Sarah Kincaid. "Kincaid" was of course used previously on the show as a surname: Claire Kincaid, played by Jill Hennessy, was the regular ADA in seasons 4 through 6, as well as Jack McCoy's lover for the last two of those seasons, before her untimely and tragic death at the hands of a drunk driver. While perhaps not odd that the writers used her surname again (there was a defense attorney named Horace McCoy prior to Jack's first appearance on the show), it does seem a bit peculiar that Jack does not have any kind of reaction to a murder victim with the name of Kincaid.
6. Maddie Corman has played three different roles over the course of the series:
   • Episode 9.22 Admissions (1999) - Melissa Slater.
   • Episode 14.6 Identity (2003) - Andee Mae Haley.
   • Episode 16.9 Criminal Law (2005) - Elaine Bowman.
7. Frank Converse has played five different roles over the course of the series:
   • Episode 2.11 His Hour Upon the Stage (1991) - Gary Wallace.
   • Episode 6.11 Corpus Delicti (1996) - Lyle Christopher.
   • Episode 9.22 Admissions (1999) - Mr. Kelly
   • Episode 14.23 Caviar Emptor (2004) - Stable Manager.
   • Episode 19.4 Falling (2008) - Wayne Hardy.

Refuge: Part 1

1. First appearance of Carolyn McCormick (Dr. Elizabeth Olivet) since the season seven episode Mad Dog (1997). This episode also marks the first time that J.K. Simmons's character, Dr. Emil Skoda, appears together with Dr. Olivet.
2. This episode appears to be based on the Russian mafia drug money laundering scams during the 1980s and 1990s between New York's JFK Airport and Russia's Moscow.
3. Nikita Khrushchev was a Soviet statesman who led the Soviet Union during part of the Cold War as the First Secretary of the Communist Party of the Soviet Union from 1953 to 1964, and as Chairman of the Council of Ministers, or Premier, from 1958 to 1964. Khrushchev was responsible for the de-Stalinization of the Soviet Union, for backing the progress of the early Soviet space program, and for several relatively liberal reforms in areas of domestic policy. Stalin's death in 1953 triggered a power struggle, from which Khrushchev ultimately emerged victorious. On 25 February 1956, at the 20th Party Congress, he delivered the "Secret Speech", which denounced Stalin's purges and ushered in a less repressive era in the Soviet Union. His domestic policies, aimed at bettering the lives of ordinary citizens, were often ineffective, especially in agriculture. Hoping eventually to rely on missiles for national defense, Khrushchev ordered major cuts in conventional forces. Despite the cuts, Khrushchev's rule saw the most tense years of the Cold War, culminating in the Cuban Missile Crisis.
4. The victim, jeweler Vasili Chuikov, is named for the Red Army commander who defended Stalingrad and ultimately accepted the German surrender of Berlin.
5. Jon Shaver (Officer Diego) also played the role of Brandon Gregory in episode 16.22, Invaders (2006).

Refuge: Part 2

1. This is the first episode of the series in which the entire regular cast appear in a scene together.
2. Sam Waterston's, son, James Waterston, plays the character of Dr. Shimo.
3. This episode marks Benjamin Bratt's final regular appearance. He would later return for one last episode in season 20's "Fed".
4. At [12:45], Det. Curtis (Benjamin Bratt ) is having a conversation with Omar Pinella (Nelson Vasquez ), a Colombian "sugar cane" seller. At the end of the conversation, Omar attempts to insult Det. Curtis during a dialog exchange in Spanish: Omar: Y eso sangre de Indio? Es Su Padré? Curtis: Tu Madré.The English translation is as follows: Omar: And the Indian blood? Your father's? Curtis: Your mother's.
5. This episode appears to be based on the Russian mafia drug money laundering scams during the 1980s and 1990s between New York's JFK Airport and Russia's Moscow.
6. This episode is Zoe Seldana's first film appearance, a 25-second scene beginning at [08:59]. Her later appearances include roles as Uhura in the Star Trek (2009) movie series, Neytiri in the Avatar (2009) movie series, and Gamora in the Guardians of the Galaxy (2014) movie series. She appeared in 4 films that broke $2 billion at box office; these are 4 of the 6 highest-grossing movies of all-time.
7. The Bomb Squad officer describes the bomb placed on the 27th precinct's oil heater in the basement as being made from a pound of Semtex (he incorrectly calls it "centex") and magnesium thermite. Semtex is a plastic explosive containing RDX and PETN (pentaerythritol tetranitrate), it is similar to C4 but is not as powerful and is mainly used for commercial applications like blasting, demolition and mining. Thermite is not technically an explosive, it is an incendiary, it works through an exothermic chemical reaction created by the interaction of certain metals when exposed to intense heat. Thermite is a mixture of either aluminum powder or magnesium powder, and a metal oxide with the most common used being iron(III) oxide; as mentioned this particular bomb used magnesium. The reaction requires extreme heat to activate (2,732 °F/1,500 °C), the Semtex was likely used to provide the heat to trigger the reaction although a pound would be excessive for this purpose, however once thermite is ignited it creates a self-sustaining chemical reaction that produces a tremendous amount of heat. Once ignited thermite can reach temperatures in excess of 4,000 °F (2,200 °C), easily melting most types of metal, making it a popular choice for military and law enforcement applications that require quickly cutting through thick metal doors and locks. If the bomb had gone off, the thermite would have almost instantly ignited all of the fuel oil in the tank, creating a very large explosion.
8. This is the only episode in the entire series where Adam Schiff appears in the cold open. He also has the last word in the cold open in this episode.
9. Brian Keane plays the part of McAlary in this episode. He later goes on to play Dr. Murphy in episodes 10.23 Stiff (2000), and 11.14 A Losing Season (2001).
10. This is one of the episodes that shows McCoy's overzealous behavior when his passion and determination get the better of him, causing him to disregard the law and even the Constitution, even though his intentions are good, and being a hit hypocritical. He has Volsky and his senior leadership arrested without charges, bail, or indictment, violating the Fourth Amendment's protection against unwarranted search, seizure & arrest, the Fifth Amendment's due process clause, the Sixth Amendment's right to a speedy trial, the Eighth Amendment's bail provisions, and the Fourteenth Amendment's due process clause; it also violates Article I, Section 6 of the New York State Constitution that requires a person arrested for a felony offense to be indicted by a grand jury. McCoy also usually takes a more liberal stance, but in this episode he hypocritically hopes to take advantage of the "more conservative views of the U.S. Supreme Court" to get them to rule in his favor, yet in the very next episode Gunshow (1999) he rails against the conservative opinion of the court that gun manufacturers can't be held liable for how their products are used as long as they sell them in compliance with the law, anymore than car, knife, liquor or tobacco companies can be. McCoy has done similar thing in past episodes, in Competence (1994) McCoy violates the Brady rule and withholds a witness statement from the defense in a case, in Deceit (1996) McCoy intentionally causes a mistrial by repeatedly questioning the defendant in a way the judge had instructed him not to, in Mad Dog (1997) McCoy disagrees with the parole board's decision to parole a serial rapist and orders the police to harass him and even considers fabricating new charges, and in Under the Influence (1998) McCoy intentionally withholds exculpatory evidence in order to charge a drunk driver who killed three people with murder one and seek the death penalty, the evidence he withheld would have reduced the charge to aggravated vehicular homicide; this leads to McCoy being called before the Bar Disciplinary Committee in Monster (1998).
11. Jack references Frank Hogan when he hints at resigning for defying Adam's orders. Frank Hogan was the District Attorney for New York County, the seat that Adam occupies, between 1942 and 1974.