The following contains spoilers for Law & Order: SVU, season 23, episode 22, “A Last Call at Forlini’s Bar,” which aired Thursday, May 19 on NBC. This article also contains descriptions of sexual assaults.
Captain Olivia Benson, despite her personal and family accomplishments, is struggling to close her doors. Speaking to her therapist, Dr Lindstrom, (gotta love a mature woman who works in therapy), they bring up both former ADA Rafael Barba and Detective Elliot Stabler – could these two be at the origin of its lack of closure? He tackles the hurt of “most of your other co-workers have stable relationships”, prompting Liv to ask him if he thinks she has intimacy issues. But the good doc is a Bensler shipper – hopefully! — and tells him she needs to see if there’s something romantic between her and Stabler already (about time!) or move on. EO gang, how are you? It’s not about what Liv wants or needs, but what does Liv deserve? Joy.
Elsewhere, Delia Hackman hastily changes the locks on her apartment to keep someone out, but it doesn’t work. Her drunken and violent husband, Ty, is waiting for her anyway. She threatens to call the cops, but he rapes and assaults her first. ADA Carisi and Detective Joe Velasco discuss Carisi’s relationship with Detective Amanda Rollins – Carisi plans to propose because he knows she’s always been the one. Later that day, Rollins encounters Delia in a panicked rage, attacking a police cruiser with a baseball bat. Between sobs, she said she didn’t want him to kill her.
Carisi, the loveable white knight, rushes to be with Rollins as she debriefs Delia’s case, offering to stay with the girls for as long as she needs. She has had ten years of domestic violence complaints filed against her husband and her recent appearance in his apartment was just his latest restraining order violation. Rollins goes to talk with Delia, and she begs her to stop him because that’s the only way she’ll know she’ll be safe from her husband. Good detectives are quick on the case and Velasco and Detective Odafin Tutuola go after the husband. They try to charm each other, with detectives pretending to believe her story, Ty lying about consent.
Back at the squad room, Rollins receives a FaceTime call from Delia, clearly under duress, as she asks to change the charges to something less serious. She’s been looking at someone else all the time, and they realize it: her abusive husband is obviously in her apartment. The team deploys as Ty tells Delia he’s not going anywhere, but he’s wrong about that and the detectives arrest him. Liv and Amanda talk to Delia, and she insists that Ty didn’t do anything this time and shouldn’t be in trouble. This poor woman was abused and gassed for a decade.
Fin and Velasco interrogate Ty and tell him that he is going to be tried not only for DV but also for rape. Ty claims, of course, that it was consensual and that Delia is a mess. Liv and Amanda tell Delia about the night. Delia says she asked him to leave; she admits that Ty smashed his head against a wall. They admit he’s smart enough to have avoided using a weapon, but they could probably get him raped.
Outside, Carisi makes the mistake of mentioning Barba, and Liv is still mad at him for standing up for Richard Wheatley months ago – and by extension, implicating Liv and Elliot’s complicated relationship in a court case. The next day, Ty gets a ridiculously low bail release but has to wear an ankle monitor. If he rapes, he goes straight to Rikers Island, and Amanda tells Delia to call 911 the second time Ty contacts her. Amanda places her in a new apartment and reflects on Delia’s loneliness. Liv lovingly asks Amanda about her and Carisi. Rollins smiled, reminding him of Stabler. They’re still a good team, after all, and good advice might be to “get a hotel room and get it out of their systems.” Once again: EO gang, how are you?! But there’s a surprise call: Delia stabbed and killed Ty. Amanda and Liv rush in, and she tells them how Ty took her phone charger and didn’t return it, and then he didn’t leave her alone. She just wanted to be free.
The next morning, Amanda visits Delia in her outfit. Despite her confinement, she finally feels safe. Her attorney arrives and Delia details the previous night how Ty took his charger, taunting her with it, and then tried to force her to perform oral sex. He went to the kitchen and Delia felt she had to pass him. She grabbed a knife for protection, and he heard her, so she stabbed him. Liv says the medical examiner said Ty had been bleeding for about 30 minutes. But Delia had to wait for her phone to charge, she said, so she couldn’t call anyone right away.
Liv and Carisi take Delia’s case to the trial division. Chief Lorraine Maxwell, who worries about Delia’s record, but Liv points out that it’s nothing against Ty’s rap sheet and that Delia has been psychologically tortured for over ten years. Maxwell is prejudiced, saying she was in a bad relationship but never committed murder. The Liv we know and love, unlike last week’s rape apologist who writes a faux pas, stands up, however, telling her that means she probably has more resources. Maxwell warns Liv that DV cases are always hard to win no matter what.
Delia’s public defender is in over her head. Liv wants to find him a better lawyer and there is only one option left that Amanda urges her to consider: Barba. So that night, Liv and Rafael meet up at a Forlini bar. Barba agrees to take the case because Rollins asked for the favor, he says. He also tells Liv that he misses her, but she’s not ready to hear it and leaves.
It’s trial day, and Dr. Truman, the medical examiner, testifies that Ty was stabbed in the back. But Barba does her job well, casting doubt in the heads of the jury that Delia knew Ty was in mortal danger and painting a good picture of Delia being a battered woman at the end of her rope. Carisi and Barba embark on a somewhat bitter and lively back and forth. Ah, the old patterns. During a break, Rollins tells Carisi that she was the one who asked Barba to take the case, and he sadly leaves. No time to unpack trouble in Rollisi’s paradise, as the court returns to session as Delia describes the events of the fateful night. She says he gave that particular weird laugh that has always preceded the escalation of violence against Ty, so she freaked out and stabbed him. She says there was not much blood, so she thought he would come back. But she didn’t want to leave him there, so she waited at the scene until her phone charged, then she called Rollins. Carisi pesters Delia with nagging questions about her choices that night. It’s his job, of course, but it’s clear that Carisi has never been trapped in an abusive relationship. How did she feel when she realized Ty was dead? Glad he’s dead, but happier she’s alive.
It’s time to resume the trial, and Barba calls his next witness, a doctor who tested Delia and found that she suffered from mental trauma, specifically neurological trauma: CTE, which could only be the result of years of traumatic injuries. This condition would also reflect the fact that a person is incapable of accounting for his actions. Barba asks her how many times Ty hit her on the head, and she asks if by bat, fist or wall? The total number is well over 50 times, but she would only be taken to the ER if she needed a set of bones. She still suffers from lack of balance, forgetfulness, difficulty performing regular tasks and more. It Works: Maxwell agrees to lower the charges, but it’s not enough for Barba. He wants all prison terms and fines removed and an apology from the City of New York. It’s done, Delia is free. And Carisi retains his Good Guy status, as he’s relieved they lost. Rollisi fixes things with a mutual “I love you”.
There’s another relationship to mend, and Benson meets Barba for the titular last call at Forlini. Liv clings to resentment, and it’s time to talk things over. He was trying to protect her, but she didn’t ask him either, she asked him not to defend Wheatley. But Barba does not understand why she is more angry with him than with Elliott. Barba continues to insist on Liv’s daddy issues and whether it clouds her feelings for Elliot. It’s not about her feelings for Stabler, she insists. Barba is a bit jealous though, that Liv loves Elliot unconditionally. And that’s something he understands because he’s always loved her unconditionally. Liv’s love triangle in season 24? She deserves it.
One more for the road to season 23: EO gang, how are you?
New episodes of Law & Order: SVU will return this fall for its record-breaking 24 season on NBC.
Law & Order: SVU Season 23, Episode 21, “Confess Your Sins to Be Free” Recap and Spoilers