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Recap / Law & Order S2 E16 "Vengeance"

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Directed by Daniel Sackheim

Written by Michael S Chernuchin, Rene Balcer, & Peter S Greenberg

A student named Judy Bream is murdered, and it's apparent that she is the victim of a serial killer who has strangled two other women. Judy had been visiting her parents in Connecticut before she died, but returned to New York when she got a call saying that her apartment needed electrical repairs. The investigation leads to Albert Cheney, who was previously jailed for strangling another woman and keeps a uniform and ID he used in his previous job as an electrician, allowing him to gain access to the victims' homes. But the evidence is circumstantial, and Cheney's wife gives him an alibi. Eventually Cheney lets slip that he rents a storage unit. The police search it and find photos Cheney took of the victims' corpses, so he is arrested. The defense gets the photos excluded from trial, and now Cheney can be charged only with Judy's murder.

Stone and Robinette further learn that Cheney's lawyer exploited a technicality to get him only five years' jail time for the death of his first victim. Judy's parents are so enraged by this that they file a motion to have him extradited to their home state of Connecticut, which has the death penalty - on the grounds that Cheney lured her away from Connecticut and this shows premeditation. However, Stone knows Cheney wasn't aware Judy was away and had forwarded her calls. Despite Schiff and Robinette feeling that allowing extradition could be the best chance of getting justice for Cheney's victims, Stone successfully petitions a civil court to dismiss the motion. But if Cheney is acquitted of the murder, double jeopardy laws prevent him from ever being tried for Judy's death again. Stone is now under intense pressure to win the case.

In court, Cheney's lawyer highlights the fact that the evidence is circumstantial. Stone has since discovered that Cheney's wife gave him a false alibi, but since there's no indication she was an accomplice, she's covered by spousal privilege. Stone convinces her to talk by showing her the photos of the victims' corpses. She is horrified and agrees to testify against her husband. Mrs. Cheney tells the jury that Cheney came home covered in blood and told her he'd been in a fight; she agreed to lie for him so he wouldn't go back to jail for breaking his parole. Cheney is convicted of murder and gets a minimum 25 years in jail.


This episode contains examples of:

  • Deadly Doctor: Dr. Banks is the detectives' initial suspect. Subverted in that he's not the killer, although a co-worker says he is so incompetent it's only a matter of time before he does kill a patient.
  • Enhanced Interrogation Techniques: The police grill a suspect (who tortured and killed four women) for 12 hours before he slips up and accidentally tells them about the storage house where he kept the pictures he took of the naked, abused women. The judge throws it out even though the police repeatedly Mirandized him, claiming that the interrogation technique was too rigorous.
  • Faux Affably Evil: Cheney is pleasant and amicable during the interview, and is a loving husband to his wife. In his downtime, he likes to strangle young women.
  • Grey-and-Gray Morality: Stone battles with this. On one hand, Cheney stands a good chance of being acquitted and will almost certainly kill again if he walks free; on the other, Stone feels the death penalty is wrong, and knows that the Breams are prepared to lie under oath to get Cheney executed.
  • Loophole Abuse: Cheney's lawyer exploited one of these to get him only five years for manslaughter when he killed his first victim. The Breams also want to game the system so they can have Cheney extradited and try to get him the death penalty.
  • Outliving One's Offspring: Judy's parents are actively trying to ensure that her murderer will never kill again.
  • Perp Sweating: Cragen and Logan try to lure Cheney into confessing by saying that the power company he used to work for have confirmed he never returned the elevator access key they gave him - so he could have thrown Judy's body down the elevator shaft where it was found. When Robinette privately questions if the company's records go that far back, Cerreta says the police haven't even spoken to them.
  • Ripped from the Headlines: This episode has some similarities to the case of serial killer Albert De Salvo, known as the "Boston Strangler"
  • Serial Killer: Albert Lawrence Cheney likes to bind and gag young women with duct tape before strangling them. He racks up four victims before he's caught.
  • Spousal Privilege: This comes up when Stone needs Mrs. Cheney's alibi. He gets around it by showing her the photos of the victims, which upsets her so much that she volunteers to testify against her husband.

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