"Limitations"
SVU, Episode 1.14
Production number: E0919
First aired: 11 February 2000
  th of 476 produced in SVU  
th of 476 released in SVU
  th of 1229 released in all  
MunchJefferiesLimitations.jpg
Written By
Michael R. Perry

Directed By
Constantine Makris

Summary[edit | edit source]

The SVU tries to close a serial rape case whose statute of limitations is about to expire. Benson and Stabler finally realize that one of the victims knows the rapist, but she's not willing to talk.

Plot[edit | edit source]

At a performance review, Cragen is criticized by the police commissioner for not solving a series of three sexual assaults that occurred almost five years ago, before he joined the SVU. The cases were recently linked by DNA. The rapist invaded each victim's apartment in the middle of the night with a stocking mask on, raped them, and maced them before fleeing. One victim, Victoria Kraft, angrily rebukes Cragen.

However, the statute of limitations on the rapes expires in less than a week, so an arrest must be made soon. The statute protects the rights of accused criminals by requiring the government to start a prosecution while evidence and witnesses are still fresh, but it long predates DNA testing.

In a bid for time, the SVU asks a judge to issue an arrest warrant for the perpetrator's DNA profile, John Doe 121. Warrants can be issued based on unique characteristics like a nickname and physical description before police know the person's actual identity, and DNA is certainly unique. A similar case in Wisconsin used this maneuver. The judge thinks it over but denies the application. What's to stop the police from bypassing the statute of limitations in every case by getting a DNA warrant?

Benson and Stabler speak to the previous detectives. The one who worked on Kraft's case tried her best, but Victoria attempted to sue her for dereliction of duty and hired a private investigator instead. Another retired cop who handled Lois Creen's rape crudely suggests that she made the whole thing up after regretting a one-night stand, and Benson walks out in disgust.

As for the victims, they all report that the rapist seemed to know a lot of intimate details about their lives, while an eyewitness saw a man in a uniform fleeing one of the scenes on a green bike. Lois also remembers a guy on a green bike following her in the weeks leading up to her attack. The squad wonders if the rapist might be a delivery man. It would explain how he was able to stalk his victims without seeming out of place.

The private investigator points them to Green Machine Bike Messengers, which went out of business after one of the workers got in an accident and the owner didn't have insurance. His old records show four deliveries to the office of the third victim, Jennifer Neal, in the week before her assault.

During another visit from detectives, Jennifer lets on that she knows who the rapist is, but doesn't want to turn him in because she says he's a changed man. She bumped into him by chance and after they spoke, as a devout Quaker, she forgave him. Benson notes that forgiveness is up to a jury, and the other victims deserve justice.

Victoria and Lois to confront Jennifer over her spiritual objection in the precinct conference room. Victoria declares her a traitor to women and threatens to pull her company's business from Jennifer's employer. When Jennifer remarks that she hopes they find peace, a sobbing Lois calls her a freak and screams at her to shut up. The SVU reluctantly seeks a subpoena to compel Jennifer's testimony; she still refuses and is jailed for contempt of court. Benson is disgusted that they locked up a rape victim, and the police commissioner isn't happy either.

Jennifer said she prayed with her assailant, so Benson and Stabler stop by the Quaker Meeting House, where the minister unsuccessfully counseled her to turn him in. Quakers are pacifists, but do not entirely shun cooperation with the justice system. Nevertheless, he says it would be an invasion of privacy to hand over their membership list. The police come back with a search warrant, where the congregation has gathered to peacefully disobey and plead with them to respect the separation of church and state.

With six hours to go before the statute of limitations runs out on the last crime, they cross-reference the Quaker membership roster to the Green Machine delivery records and find Harvey Denis. He served time for burglary—possibly a foiled fourth attack—but was released after he himself was brutally raped in prison. When the detectives go to arrest him, they find him in a wheelchair; he was paralyzed in a bike accident. As Stabler lifts him into the back of the car and reads Denis his rights, Benson has an ambiguous look on her face.

Cast[edit | edit source]

Main cast[edit | edit source]

Recurring cast[edit | edit source]

Guest cast[edit | edit source]

References[edit | edit source]

Quotes[edit | edit source]

Counsel Eastman, Captain Cragen. I find your application for an arrest warrant ingenious. The statute of limitations has a long history in common law. It exists to ensure that the defendant receives a fair trial, to make sure that the recollections of witnesses, if any, are fresh, to pressure the government to press charges in a timely manner and so that, rightly or wrongly, accused citizens need not live their life in fear of the government pursuing them after a long delay. But when these laws were codified, we did not have the technological marvels that exist today. Your application is a novel idea. However, it is not the role of this court to evaluate novel ideas. And as such, I cannot grant your application.

–Judge Alan Ridenour about the statute of limitations


Elliot Stabler: Alright, we're going to talk to some of the detectives who originally investigated.
Donald Cragen: Munch, that okay with you?
John Munch: Sure, it'd be like visiting the Special Victims Unit alumni association. All the people that used to sit at these desks. Where are they now?



You prayed with your rapist?

–Elliot Stabler to Jennifer Neal

Background information and notes[edit | edit source]

  • The statute of limitations is a legislative act restricting the time within which legal proceedings may be brought, usually to a fixed period after the occurrence of the events that gave rise to the cause of action. Such statutes are enacted to protect persons against claims made after evidence has been lost, memories have faded, or witnesses have disappeared. The periods prescribed for different actions in different jurisdictions vary considerably. (source = Britannica)
    • Two crimes that have no statute of limitations are murder and kidnapping.
  • The opening credits for this episode have been changed to include Michelle Hurd.
  • This is the first appearance of Peter Francis James as Judge Kevin Beck. He would play this role for a total of five episodes in the first and second seasons. James also appeared in episodes from Law & Order and Law & Order: Criminal Intent.
  • This is also the first appearance of Harvey Atkin as Judge Alan Ridenour. Atkin appeared as the same character in two episodes from Law & Order: Criminal Intent.
  • Actress Leslie Ayvazian appears for the first time as Judge Susan Valdera. Ayvazian played the same character on Law & Order, and appeared throughout the Law & Order franchise in different roles.
  • Goof: Michael Marisi Ornstein is credited as "Charles Denis" but is first name is given as Harvey in the episode.
  • Goof: On Amazon Prime Video in Australia, when Victoria Kraft says she was raped on February 8th, the subtitles instead say February 13th. This is most likely an error on Amazon Prime Video's part.

Episode scene cards[edit | edit source]

1 2 3 4

Apartment of
Lois Creen
124 East 26th Street
Monday, February 7

Eastern Health Services
79 West 55th Street
Monday, February 7

Kraft International
Electronics
299 East 65th Street
Monday, February 7

Supreme Court
Trial Part 55
Monday, February 7

5 6 7 8

31st Precinct
Robbery Unit
Tuesday, February 8

The Ten Thirteen
Elmhurst, Queens
Tuesday, February 8

Appellate Division
First Department
Wednesday, February 9

Millennial Investigations
49 East 28th Street
Wednesday, February 9

9 10 11

Clean Machine
Laundromat
432 West 48th Street
Wednesday, February 9

Supreme Court
Trial Part 41
Thursday, February 10

71st Street Meeting House
43 West 71st Street
Friday, February 11


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Law & Order: Special Victims Unit
Season 1
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