History Main / CardboardPrison

* ''ComicStrip/{{Dilbert}}'' has a similar situation to ''WesternAnimation/TheSimpsons'' example below, when Wally is imprisoned, and Dogbert tells him that the guards just pretend to lock it up. As Wally said, "I'd have to say, the lifers were the most embarrassed."

* Comicbook/ThePunisher occasionally finds himself thrown in jail, but it's usually part of a BatmanGambit to kill a crime lord who's already behind bars in the same prison (for example: the final level of the video game). One time {{Daredevil}}, Franchise/SpiderMan, and {{Wolverine}} all teamed up in an attempt to stop the Punisher once and for all, but at the end of the battle the Punisher [[LampshadeHanging points out that]] if they put him in jail he'll just kill every inmate in the prison before escaping again. [[Awesome/ThePunisher The three heroes agree and let him go.]]

* In [[http://scans-daily.dreamwidth.org/956653.html?#cutid1 a comic]] based on ''WesternAnimation/BatmanBeyond'' featured on Scans Daily the Royal Flush Gang are out committing crimes when they are supposed to be in prison. Terry doesn't know how they could have escaped noting, "This place is locked up tighter than a drum." Despite the outcome, Terry's comment still seems like an odd thing to say when Bruce Wayne has told you all about his past, with one person posting, "Uhh, Terry? You got in, didn't ya?"

* Any prison is this for {{Diabolik}}. The first time he had been arrested (alluded in his first story and shown in a flashback years later) it had been because his [[LatexPerfection perfect masks]] weren't known yet, so the police didn't realize he was wearing one and he walked out of a maximum security prison with a stolen guard uniform after taking the mask off, but later imprisonments, happened after his masks and real face were known, all ended with him breaking out rather easily in spite of always increasing measures to keep him long enough to execute him, with a JerkassVictim getting executed in his place once.
* In the [[ComicBook/TeamSeven Team 7]] series, a floating (seemingly inescapable) prison was created for the purpose of holding metahumans. Furthermore, it was powered by inertial fusion. Not only was the alternative energy prohibitively expensive, but the prison failed to protect its workers/inmates from an Eclipso infestation.
* Comicbook/{{Asterix}} and Obelix can't be held by iron bars, as Obelix will just smash his way out once they've gotten their bearings. In fact, just ''arresting'' the two Gauls is a feat in itself...or a sign that Asterix wants to play along for the mission their on.

** The same episode has Jack Dalton coming back to his cell and leaving again three times while one of the warden is still trying to close the hole from their last escape. The Warden just let him tale what he needs a go away without even trying to stop him.
* The first time in DC Comics that the Crime Syndicate of Earth 3 showed up, they were beaten and imprisoned in a bubble created by Franchise/GreenLantern, and THEN thrown into a limbo between dimensions/earths. They kept somehow breaking out and causing trouble.
** Not that often and, at least the first time, only after outside interference. Johnny Quick, Power Ring, and Superwoman managed to escape from the bubble after an interdimensional traveler passed by and somehow weakened it (no real details given). That was about 14 years after their first appearance (real time; in comic time, it could have been anything from a week and a half later). A couple of years later, Ultraman got out, but nothing at all was said about how. Owlman wasn't seen again until the Crisis, and could well have been stuck in the bubble the whole time until the entire Syndicate returned home in time to die in the destruction of Earth-3.
* French comic book ''Le Mercenaire'' contains a literal example of a cardboard cell. The hero is imprisoned inside a flying castle, which is in fact a giant hot-air balloon. Hence, everything is constructed of light and hollow material, including the large jar used as cell, which is thick cardboard. The prisoner was relieved of any item that could pierce it beforehand (including his belt buckle), but can cut through once he receives exterior help (in the from of dagger).
* Justified in the case of {{the Silver Age|OfComicBooks}} MadScientist version of Lex Luthor, who was fond of MacGyvering a [[AppliedPhlebotinum Phlebotinum]]-powered escape device out of absolutely ''anything''. Writer ElliotSMaggin once had Luthor muse that it had reached the point where the only two items his guards would allow him to have were a pen and a pad of paper. Luthor had, in fact, long since figured out a way to turn the ink, metal, plastic, and wood pulp into a high explosive to blast his way out, but he would never ''do'' so, because then the next time Superman threw him in prison, the prison wouldn't let him have a pen and paper any more.

** One [[TheGoldenAgeOfComicBooks Golden Age]] [[Comicbook/{{Shazam}} Captain Marvel]] comic has ''his'' bald MadScientist adversary, Dr. Sivana, sitting in prison grumbling that there's no point in escaping because Captain Marvel will only catch him again. He then thinks up a plan to destroy Captain Marvel and, his mood brightened, easily escapes by simply ''performing a mathematical calculation in his head'' that "opens a portal to the fifth dimension" and then walks out through a wall like a ghost.
** In Franchise/JusticeLeagueOfAmerica #5 Monty Moran 'the Getaway Mastermind' breaks himself and 5 other supervillains out using a shrinking ray he somehow built that makes them half an inch tall. Then they use a balloon with a container underneath to get out.
* It is slightly better in Strange Tales #105 where the Wizard becomes a trustee, makes a formula that eats through stone from chemicals in the Medical area, then hides in his cell while the guards rush through leaving the door open.

* The ''Comicbook/LuckyLuke Rantanplan]]'' spin-off even has an episode where people succeed in ''kidnapping'' Averell Dalton without much problem. They don't just fail at preventing their prisoners from getting out, they also fail at keeping people from coming ''in'' to take their prisoners forcefully. Even Joe is outraged by such a degree of ineffectiveness.

* Justified in the case of TheFlash's Rogues Gallery by the fact that one of them can travel to an alternate dimension and back via mirror. Every time the Flash arrests any of his friends, Mirror Master goes and fetches them right back out again. The warden explains that they've tried to have the mirrors removed but prisoner-rights liberals won't have it.

** The Vault has now been replaced by the Raft. It was first introduced in the first arc of Comicbook/NewAvengers. Said arc is about a massive jail break.
*** A running subplot was Mayor J. Jonah Jameson shutting the Raft down, noting how much of a failure it was. In ''ComicBook/SuperiorSpiderMan'', its last duty was to execute Alistair Smythe, the Spider-Slayer, only for him to execute a prison break. In short order, [[spoiler: Ock!Spidey kills Smythe, blackmails Jolly Jonah for giving him that order and takes control of it, turning it into Spider-Island II]].
* This was {{Lampshaded}} in the ''YoungAvengers / {{Runaways}}'' crossosver during ''Comicbook/CivilWar''. The Runaways end up fighting Flag-Smasher, only for Karolina to bemusedly point out that the kids had ''just'' beaten him and sent him off to prison only a few months prior.
* "Prison 42", nicknamed "Fantasy Island" by its inmates, debuted in ''Comicbook/CivilWar''. It's located in another dimension, accessible only by certain teleporter systems, secure and heavily coded. Many superheroes unwilling to register with the government were locked up there, and were indeed its first inmates. It was supposed to be the final answer to this trope. Naturally, the anti-registration heroes on the outside engineered a mass jailbreak. Likewise it serves to be a sort of {{deconstruction}} of [[IDidWhatIHadToDo what steps you would have to take]] to actually make a prison immune to the kind of crazy shit filling the Marvel Universe.
** As [[IKnewIt predicted]] by some annoyed fans, it later got taken over by the ''residents'' of the Negative Zone.
* The prisons of the ''Comicbook/LuckyLuke'' comic, especially the Penitentiary. [[TheGuardsMustBeCrazy The Wardens are a bunch of incompetent morons]], their dog is even stupider than they are, and the prisoners, especially [[ArchEnemy the Daltons]], escape constantly, sometimes right after being brought back to jail. They even managed to accidentally free Joe Dalton once. This is subjected to frequent LampshadeHanging, to the point Luke gets sick of it in later albums.
** The ''Rantanplan'' spin-off even has an episode where people succeed in ''kidnapping'' Averell Dalton without much problem. They don't just fail at preventing their prisoners from getting out, they also fail at keeping people from coming ''in'' to take their prisoners forcefully. Even Joe is outraged by such a degree of ineffectiveness.

* Both Lucia and Gale (King) Raregroove broke out of a prison at some point in ''Manga/RaveMaster''. King escaping a regular jail only three days after being locked up so he could get back at the other Gale. Lucia busts apart a maximum security prison (it's implied that he broke a several feet thick metal wall with his bare hands-he's just that BadAss) ten years later, waiting that long only because he had nothing better to do for that stretch of time.

*** ''ArkhamAsylumLivingHell'' had Commissioner Gordon outraged by the fact a villain called Doodlebug was released, who then added insult to injury by having graffittied "Gone to Arkham. Back after lunch" on a wall in an in-universe lampshade of Arkham's security. [[spoiler: It should be noted that the "doctor" who issued Doodlebug's release was a imposter who'd killed the real doctor before the story, adding to Gordon's point.]]

*** In the ''WesternAnimation/BatmanTheBraveAndTheBold'' adaption of that story, Batman says he designed Joker's new cell himself and that he won't be getting out. Bat-Mite uses his RealityWarper abilities and Joker is loose again. This may explain the trope itself.
*** After ''Joker: Last Laugh'', StatusQuoIsGod got invoked and subsequent stories would see the Joker once again being housed in Arkham.

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* ''Series/{{Supernatural}}'' portrays Hell as rather ineffective at containing demons. Demons who are exorcised back to Hell pop back up to cause trouble again [[TravelingAtTheSpeedOfPlot at the Speed of Plot]] (e.g. Meg, Ruby, Alastair, Lilith). Considering who is in charge down there, this is probably deliberate. Lucifer's cage also qualifies if you take his army of fanatically loyal minions into account. Combinatorial calculations yield at least 1.22 x 10[[superscript:87]] distinct methods by which he could be freed. (This figure assumes that there are exactly 600 seals, that the first and last seal are fixed, and that breaking the same seals in a different order doesn't count as different.) On top of that, the actual seals include things like a "righteous man" (read "Dean Winchester") shedding blood in Hell in a canon where BeingTorturedMakesYouEvil and one of the aforementioned fanatically loyal minions sacrificing herself for the cause. Accordingly, springing Lucifer is as easy as [[IfYoureSoEvilEatThisKitten baby kitten pie]]. Again, given who is in charge of the imprisonment, this is deliberate.

*** In the ''BatmanTheBraveAndTheBold'' adaption of that story, Batman says he designed Joker's new cell himself and that he won't be getting out. Bat-Mite uses his RealityWarper abilities and Joker is loose again. This may explain the trope itself.

** The trope isn't just limited to this galaxy, either. When questioned on her reappearance, as she was supposed to be locked up in some galactic prison, Blackfire nonchalantly commented, "I got bored, so I broke out."

* Then there's SelfDemonstrating/LexLuthor. In the film version of ''AllStarSuperman'', he tells Quintus that if he wanted to leave prison, he would have hours ago.

** Strong Mad also baked a jackhammer into a "cake" for Strong Bad, but it turned out to be unnecessary. He is left standing there looking at the cake and [[DumbMuscle still confused as to why Strong Bad didn't want it]].

* In ''Film/WreckItRalph'', Fix-It Felix Jr. is locked up in the [[LevelAte Sugar Rush]] [[IncrediblyLamePun Fungeon]]. As he laments, he notices that the bars on his window are loose. He whips out his hammer, and strikes the bars. [[SubvertedTrope They become]] [[MrFixIt twice as]] [[BlessedWithSuck thick.]]

Contrast with LuxuryPrisonSuite (in which the character might not ''want'' to leave prison, because of how nice it is), MightAsWellNotBeInPrisonAtAll (in which the character doesn't have to leave the prison to remain a threat), and PlayAlongPrisoner (in which the character doesn't ''currently'' want to leave the prison, but could if and when that changes). Also contrast TheAlcatraz, which actually ''is'' hard to escape from, but possible (see GreatEscape) and TailorMadePrison, which is specifically designed to hold a character who could easily escape an ordinary prison. This problem is frequently solved via {{Self-Disposing Villain}}, and the occasional HeelFaceTurn.

** One story featured a ghost who kept breaking out of the ghost traps no matter what the Ghostbusters tried. Ultimately he turned out to be the Ghost of HarryHoudini and fortunately was actually a good guy, negating the need to try putting him in the containment unit.

* HarryHoudini claimed (and was able to back up) the ability to escape from anywhere. He toured England, Scotland, the Netherlands, Germany, France, and Russia. In each city, Houdini would challenge local police to restrain him with shackles and lock him in their jails. In many of these challenge escapes, Houdini would first be stripped nude and searched. A police officer is reported to have said he was ''very'' glad Houdini was not actually a criminal.

* The prisons of the ''Comicbook/LuckyLuke'' comic, especially the Penitanciary. [[TheGuardsMustBeCrazy The Wardens are a bunch of incompetent morons]], their dog is even stupider than they are, and the prisoners, especially [[ArchEnemy the Daltons]], escape constantly, sometimes right after being brought back to jail. They even managed to accidentally free Joe Dalton once. This is subjected to frequent LampshadeHanging, to the point Luke gets sick of it in later albums.

** Justified. In "A Day Unlike Any Other", [[spoiler:oi reveals he caused the breakout to keep Thor busy while he took over Asgard.]]

* Done with ''Manga/AxisPowersHetalia'', where Germany can dig his way out of a prison. England also manages to escape from prison because his Italian guards don't pay attention, but he always gets dragged back by Germany.

* ''TabletopGame/{{Monopoly}}'' features one of these with its jail. To get out, you only have to pay $50, roll doubles, use your GetOutOfJailFreeCard, or just wait three turns. It subverts this trope as well, because since you can't move around the board landing on expensive rival-owned properties, jail is actually [[LuxuryPrisonSuite the best place to be]].
** [[FridgeLogic Depending on personal degree of cynicism, the $50 is either paying the fine, or paying the bribe.]]

** After becoming a RealityWarper in the ''Comicbook/EmperorJoker'' storyline, the Joker is sent to a real prison, Slabside Penitentiary, which is nicknamed "the Slab". Supposedly, no villain has ever broken out of it. In ''Joker: Last Laugh'', the Joker is informed that he has terminal cancer. It takes him all of about five minutes to think up a plan to not only break himself out, but break out most of the other villains with him, ''and'' use the prison's own anti-riot countermeasures to "Jokerize" them all. Maybe Franchise/TheDCU's prisons aren't cardboard prisons. Maybe the Joker is just that good.
*** The two aren't mutually exclusive.

** Also lampshaded in "WhateverHappenedToTheCapedCrusader" by Alfred:

* Intermittently, Franchise/TheDCU attempts a solution to both the in-character problem of {{Cardboard Prison}}s and the metafictional problem of [[VillainDecay keeping losing villains effective]], [[BoxedCrook by having villains perform missions as part of the US government top-secret Task Force X, a.k.a.]] Comicbook/SuicideSquad. This program offers early releases for imprisoned supervillains if they participate in, and survive, extremely dangerous secret missions that are subject to official denial. Thus, the villains temporarily become AntiHero protagonists.

* "The Vault" was the Franchise/MarvelUniverse's most secure prison, but it was still a CardboardPrison, with any villain escaping as needed for various comic book plots. [[TropeNamers Its cardboard nature]] was actually [[http://groups.google.com/group/rec.arts.comics.marvel.universe/msg/97d5f38002cf6fde commented on]] by writer Creator/KurtBusiek, as the reason the writers had it destroyed. After its destruction and the resulting mass escape (the final shredding of the cardboard, if you will), supercriminals were incarcerated in lesser prisons nationwide, with predictable results.
* Subverted in the alternate reality book ''Punisher Kills The Marvel Universe'', where Punisher kills most if not all of the Vault's inmates by [[TeleportersAndTransporters teleporting]] [[DrowningPit a giant flood]] inside the prison.

* "Prison 42", nicknamed "Fantasy Island" by its inmates, debuted in ''Comicbook/CivilWar''. It's located in another dimension, accessible only by certain teleporter systems, secure and heavily coded. Many superheroes unwilling to register with the government were locked up there, and were indeed its first inmates. It was supposed to be the final answer to the CardboardPrison. Naturally, the anti-registration heroes on the outside engineered a mass jailbreak.
** Likewise it serves to be a sort of {{deconstruction}} of [[IDidWhatIHadToDo what steps you would have to take]] to actually make a prison immune to the kind of crazy shit filling the Marvel Universe.

** In JusticeLeagueOfAmerica #5 Monty Moran 'the Getaway Mastermind' breaks himself and 5 other supervillains out using a shrinking ray he somehow built that makes them half an inch tall. Then they use a balloon with a container underneath to get out.

** Averted in ''[[TheUltimates Ultimate Avengers]]'', however. The Punisher is locked up, seemingly for good, and only gets out once NickFury recruits him as part of his black-ops team. The bargaining chip he used to get the Punisher to agree? 24 hours alone with the keys to every cell in the complex.

* Mostly averted with the now-defunct {{Stormwatch}}, who under Henry Bendix's leadership placed supervillains in cryogenic prison without trial.

* In ''LawAbidingCitizen'', protagonist Clyde Shelton (Gerard Butler) checks in and out of a so-called maximum security prison through [[spoiler: hidden access points that he built into said prison himself]].

* In the remake of ''Film/ThreeTenToYuma'', the titular prison fits this trope. It is established late in the film that wanted gang leader Ben Wade (RussellCrowe) has already escaped from the prison Yuma at least twice before the events of the movie. After [[spoiler:Dan Evans and Wade's posse die]], Wade willingly steps onto the train and sets off on his trip towards the prison -- but ''not'' before he calls his faithful horse to ride alongside the train, proving that as soon as the film ends, he'll simply escape again.

* In one of EnidBlyton's ''Magical Faraway Tree'' books, a character is put in jail in The Land of Goodies for eating part of someone's house (which is made out of sweets). Predictably, he just eats his way out of the prison.

** The second ''{{Eisenhorn}}'' novel is an interesting example, because it changes depending on perspective. The title character is incarcerated in the most secure prison in the second most fortified planet in the galaxy, and is still freed in a matter of hours after his allies implement their plan. However, he was in the prison for about three months, and it is entirely plausible that they spent all of that time planning and simply decided it was safer not to tell him.

* In ''VideoGame/BatmanArkhamAsylum'', the intro takes pains to show off Arkham's new "improved" security system. It takes all of 10 minutes for the Joker to not only break his bonds, but take over the asylum and free all of the inmates. In fairness to the Arkham staff, a good bit of work had already been done for him. He arranged a fire at the Gotham prison to get his mooks on the island, and Harley already had control over the security system.
** Mostly it serves as a massive WorfBarrage as soon as the credits finish rolling. If the Joker just overpowered this small army with no significant casualties, what chance does one guy with a bunch a toys have?

* In ''VideoGame/MetalGearSolid3SnakeEater'' you break out of not just a jail cell, but a military base with only one eye, no clothes, a fork, a Single Action Army with no ammo, and some rations.
** Made a great deal less impressive by how your cell guard is [[TheGuardsMustBeCrazy an ancestor of Johnny Sasaki]].
* In ''VideoGame/TalesOfSymphonia'', you break out of several prison cells. One early in the game by shooting the guard with the Sorcerer's Ring (which your captors didn't take for some reason). Again [[spoiler: after getting captured by Kratos. This time Regal breaks you out using a super-awesome kick ass mega powerful ability that he vowed never to use in battle]]
** The Sorcerer's Ring looks just like a simple ring, them not taking it makes sense; they most likely didn't expect it to shoot fireballs. The real FridgeLogic is that they left his [[RingOfPower Exsphere]] on him (unlike the Sorcerer's Ring, there's no way they can't know he has it or what it does). However the biggest piece of FridgeLogic is that the Sorcerer's Ring is a holy item, [[TheChosenOne Colette]] should have it (made even worse when you learn that it's needed to progress through the dungeons)

* In the video game of ''WhereInTimeIsCarmenSandiego'', all the prisoners you've managed to capture in the first half are conveniently busted out by Carmen so you have to capture them again in the second half. The bars of the prison are upgraded after that.

* The jail system in VideoGame/TornCity is a complete joke. Even brand new players have little to no trouble breaking out (or being broken out by a friend) and the time they would have to serve is meager anyway.

** Inverted when Roy suggests locking up the Linear Guild, on the grounds that in a world of DeathIsCheap, killing their prisoners would actually be ''less'' effective than locking them up. Once your allies can start casting Resurrection, the afterlife itself becomes a CardboardPrison. [[spoiler:And he might have been right if said prison wasn't almost immediately destroyed by an invading army.]]

* In ''FauxPas'', [[http://www.ozfoxes.net/cgi/pl-fp1.cgi?354 Stu justly brags that no one ever built a make-up case that could hold him.]] (Foolish humans, thinking you can just put a rabbit in a box.)

* In ''AntiheroForHire'', this trope is critical for Shadehawk's financial health. He gets paid for thwarting criminals. Every time a criminal either escapes prison or somehow obtains legal early release, he can get paid for thwarting their next scheme. If the supercriminals stayed thwarted, he'd run out of lucrative schemes to thwart and go bankrupt. This is also why he tries to take major criminals alive.

* Sideshow Bob on ''WesternAnimation/TheSimpsons'' is constantly getting out of prison by one way or another. One episode revealed that the Springfield Minimum Security Prison has an unlocked gate, and the only thing keeping prisoners inside is the honor system. Fellow prisoners yell at Snake for "ruining it" for the rest of them when he escapes to take revenge on Homer for filling his car up with cheap gasoline.
** Bob has only really escaped twice: once by sneaking away while working at the Air Force base and once by [[Film/FaceOff disguising himself as his cellmate]]. More often than not he was released legally, albeit for highly questionable reasons: "No one who speaks German could be an evil man! Parole granted!"

** One story featured a ghost who kept breaking out of the ghost traps no matter what the Ghostbusters tried. Ultimately he turned out to be the Ghost of Harry Houdini and fortunately was actually a good guy, negating the need to try putting him in the containment unit.

* ''WesternAnimation/TheFairlyOddParents'': Though not a villain, Cosmo leads to an example of this when Wanda tricks him into a dog carrier when he needs to go to the D-O-C-T-O-R. Multiple times, it shows him easily having the ability to escape the trap, but he's too clueless to take any of the opportunities.
** Worse then it sounds; he does escape it a few times, just to show how "inescapable" it is...only to go right back in

** It's a little hard to catch, due to Spidey's tongue being burnt, but in the episode Reinforcement, he says something along the lines of "Beaky!? Is there a revolving door at that prison!?"
* In the old ''Birdman'' cartoon, a GadgeteerGenius once broke out of prison by constructing a suit of PoweredArmor complete with a jetpack in the prison metalshop. After Birdman kicked his ass and sent him back to prison the episode ended with the warden deciding to assign the guy to prison laundry duty instead of the metalshop, thinking the guy wouldn't be able to turn this to his advantage. The villain proved him wrong in a later episode when he escaped again ''by converting a dryer into an escape rocket''. After Birdman caught him ''again'', the warden finally wised up and sent the villain to work in the prison library, far away from any machinery.
* This happens in ''WesternAnimation/AvengersEarthsMightiestHeroes'' in the very "first" episode. There's a massive jail break at the four supervillain prisons (The Vault, The Cube, The Big House, and The Raft) which creates the need to form The Avengers. We don't know the history of the prisons beforehand aside from the fact that they were tailor made based on the type of supervillain they held. (The Vault had tech criminals, the cube radiation criminals, the big house genetic villains, and The Raft had the most dangerous criminals) Seeing how someone broke into the Vault in one of the backstory micro episodes, and two inmates had apparently broken out of the Cube in the past (Hulk and Absorbing Man), they don't sound too great.
** Regardless, all these prisons are presumably abandoned for prison 42, the above mentioned "fantasy island" of comic fame. Unlike comics, this prison has functioned just as designed, and despite the less than friendly environment, is generally considered a good idea in universe.
** Justified. In "A Day Unlike Any Other", [[spoiler:Loki reveals he caused the breakout to keep Thor busy while he took over Asgard.]]

* Harry Houdini claimed (and was able to back up) the ability to escape from anywhere. He toured England, Scotland, the Netherlands, Germany, France, and Russia. In each city, Houdini would challenge local police to restrain him with shackles and lock him in their jails. In many of these challenge escapes, Houdini would first be stripped nude and searched. A police officer is reported to have said he was ''very'' glad Houdini was not actually a criminal.

** This is one version of the story, anyway. According to another he bribed a guard to give him a gun, and made up the story in order to cover for him. And in ''{{Illuminatus}}''-trilogy he claims that he walked through the walls.

* In ''{{Fingerprints}}'', a heavily drugged prisoner manages to ''just wander out'' during a computer malfunction. Yes, it was a makeshift prison being maintained by just one person, but still: ''epic failure''.

And you can walk right out again as soon as you are in''

[[quoteright:262:[[WebAnimation/HomestarRunner http://static.tvtropes.org/pmwiki/pub/images/jaila.jpg]]]]

Perhaps a necessity in stories which feature a RoguesGallery, since you need to find a way to keep bringing them back but have the heroes seem somewhat effectual. This was particularly true in comics in the days when the ComicsCode held sway -- the villain had to be clearly defeated at the end of each and every appearance, requiring an escape from either incarceration or [[NoOneCouldSurviveThat apparent death]] before he could show up to vex the heroes again.

* Subverted in the alternate reality, Punisher Kills The Marvel Universe, where Punisher kills most if not all of the Vault's inmates by teleporting a giant flood inside the prison.