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Recap / Law & Order: Special Victims Unit S4 E22 "Futility"

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An accused rapist turns out to be a formidable opponent for Cabot after he decides to represent himself in court.


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  • Ambiguous Ending: It's heavily implied that Erin Russ murdered Michael Gardner in anger after finding out he really was guilty, but it's neither established with certainty nor do we learn what happens to Erin.
  • Amoral Attorney: Erin Russ is having an affair with her client, Michael Gardner. She also knew where he was after he fled from the trial.
  • Asshole Victim: Michael Gardner. Possibly. Detectives seemingly invoke this by telling Erin she had no choice and emphasizing that it was self-defense, despite the implication that she murdered him.
  • A Fool for a Client: Michael Gardner defends himself, but he's actually pretty good because Erin Russ is helping him.
  • Serial Rapist: Michael Gardner
  • Villainous Breakdown: Upon learning that Carrie Huitt has decided to waive her right and allow Bethany to testify, and that the judge has decided that Bethany did not influence Carrie's identification of him as her rapist, Gardner loudly tries to object, and when the judge tells him he can't, he screams, "No! That's not fair!"
  • Villain with Good Publicity: Gardner appears to be a mild-mannered Nice Guy, and many of his supporters have difficulty believing he's actually a sexual predator.

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