Home Blog Page 20

Saving The Child from the Client on the Mandalorian

0

How do you atone for the sin of turning a child over to fascists for medical experimentation that would be a war crime? In the Mandalorian’s case, you go save the kid in a way that makes Clint Eastwood in Unforgiving look restrained.

Spoilers ahead for The Mandalorian, Chapter 3, The Sin.

Did the Mandalorian have a Duty to Rescue Child from the Imperial Remnant?

The law does not impose a duty to rescue a stranger absent a special relationship. Moreover, there is no duty to protect others from the criminal acts of third parties. Folsom v. Burger King, 135 Wn. 2d 658, 674-75 (Wash. 1998), citing W. PAGE KEETON ET AL., PROSSER AND KEETON ON THE LAW OF TORTS § 56 (5th ed. 1984) and Hutchins v. 1001 Fourth Ave. Assocs., 116 Wn.2d 217, 223 (1991).

A “special relationship” can arise when one party is entrusted with the well-being of another individual. Folsom, *675, citing Lauritzen v. Lauritzen, 74 Wn. App. 432, 440, 874 P.2d 861 (1994). One of those situations is when someone has a custodial relationship to another. Stangle v. Fireman’s Fund Ins. Co., 198 Cal.App.3d 971, 974-75 (Cal. Ct. App. 1988), and Rest.2d Torts, § 314A.

The Mandalorian arguably had developed a custodial relationship with the Child based on the following events: finding the Child; protecting the Child from IG-11; protecting the Child from the Trandoshan bounty hunters; and refusing the Jawa offer to take the Child in exchange for the stolen parts to the Razor Crest. During this entire series of events, the Mandalorian had a custodial relationship with the Child. Moreover, the Mandalorian’s actions arguably put him “in loco parentis” to the Child, which is when “to a person who has put himself in the situation of a lawful parent by assuming the obligations incident to the parental relation without going through the formalities necessary to legal adoption.” Fuller v. Fuller, 247 A.2d 767, 770 (D.C. 1968), citing Niewiadomski v. United States, 159 F.2d 683, 686 (6th Cir. 1947), cert. denied, 331 U.S. 850, 67 S.Ct. 1730, 91 L.Ed. 1859. Moreover, “in loco parentis” only arises when someone is “willing to assume all the obligations and to receive all the benefits associated with one standing as a natural parent to a child.” Id.

The Mandalorian provided the Child safety and security while the Child was in his care. Moreover, the only time the Child cried was when Stormtroopers took the Child away for medical experimentation. Based upon the above series of events, The Mandalorian had developed a “special relationship” with the Child, which mandated rescuing the Child from the Imperial Remnant.

Was the Mandalorian’s Raid on the Imperials Justified under the Defense of Others?  

Yoda said to Luke Skywalker, “A Jedi uses the Force for knowledge and defense, never for attack.” The Mandalorian did not get that memo. Moreover, an attack on an aggressor upon another could justify an attack upon the aggressor under the defense of others. The question is whether the defense of others justified the Mandalorian raiding an Imperial compound to rescue the Child.

A person has engaged in perfect defense of others – and is not guilty of homicide – if he kills a person with, “an honest and reasonable belief in the need to defend himself or others from great bodily injury or death.” People v. Garcia, B259708, at *6-7 (Cal. Ct. App. Dec. 28, 2016), citing People v. Valenzuela 199 Cal.App.4th 1214, 1227 (2011), quoting People v. Flannel (1979) 25 Cal.3d 668, 674-675; § 197, subd. 3. The subjective belief of danger negates the malice necessary to make the homicide murder, which then turns to the issue of whether that belief was reasonable. Garcia, citing People v. Rodriguez 53 Cal.App.4th 1250, 1269 (1997).

Did the Mandalorian have an honest and reasonable belief that he needed to defend the Child from the Imperials? The Mandalorian watched with his infrared scope, that also picked up audio, a conversation between the Client and Dr. Pershing directing the Doctor to quickly extract the necessary material from the Child because the Client could no longer guarantee Dr. Pershing’s safety. Coupled with every Bounty Hunter having been retained by the Client to terminate the Child, the Mandalorian did have an honest and reasonable belief the Child was in mortal danger from the Client having Dr. Pershing conduct a medical procedure that could kill the Child. This reasonable belief would negate the malice required for murdering fourteen Stormtroopers and makes his use of force justifiable in order to save the Child.

Let’s not forget the Imperials were the ones who had blown up planets and waged wars on civilian populations in their Doctrine of Fear. It would be unreasonable to not see them as an imminent threat to anyone in their custody.

Self Defense Against Bounty Hunters

The entire Bounty Hunters Guild all had tracking fobs activate after the Mandalorian rescued the Child from the Imperials. This resulted in the Bounty Hunters confronting the Mandalorian and a shootout with at least sixteen other Bounty Hunters.

The doctrine of self-defense requires a person to reasonably believe that their safety was endangered. Over a dozen Bounty Hunters surrounded the Mandalorian. The Client had retained those very same Bounty Hunters to kill the Child. Moreover, Greef Karga had stated earlier the other Bounty Hunters wanted the Mandalorian dead for his success in finding the Child. Furthermore, during the shootout Karga also stated a threat to kill the Mandalorian and strip his body for parts. There was more than enough of a reasonable belief for the Mandalorian to fear for his life, and that of the Child, for him to claim self-defense in his gunfight with the Bounty Hunters.

Employee Free Speech Protections in Jedi: Fallen Order

0

“I’ve been working on this heap a long time. Way before the war. We refit and rebuilt ships. Best in the galaxy. Then came the Empire. And engineers became scrappers. The workers just started getting worked. But we all know the truth. We’re just too afraid to say it. To the Empire, we’re all just expendable.

Prauf, Jedi: Fallen Order

The expository first level of Jedi: Fallen Order takes place on the world of Bracca, a junkyard planet covered in derelict vessels waiting for salvage and demolition. The story finds our protagonist, padawan-in-hiding Cal Kestis, living as a scrapper and chumming around with his colleague, a kindly older alien named Prauf. After Cal instinctively uses the Force to save Prauf from a harrowing industrial accident, their crew is rounded up for inspection by a squad of Imperial Jedi hunters led by the Second Sister. When Prauf is foolhardy enough to stand up to the Second Sister and deliver the above-quoted speech to his fellow coworkers, Prauf is subjected to an extreme form of retaliatory workplace discipline: let’s call it “termination.”

In a less fascist society, Prauf’s challenge to the conditions of his employment may have been subject to legal protections that would have prevented or provided a remedy for his termination. Fortunately, issue-spotting this fact pattern is infinitely less difficult than catching a rope to cross a gap in Fallen Order

Free Speech

First, the Second Sister’s style of employee discipline may have violated Prauf’s constitutional rights. Prauf’s dialogue implies that the Empire had taken control of the Bracca scrapyards, which may have transformed the employer into a governmental entity. The First Amendment of the U.S. Constitution prevents the government from abridging the right to free speech, subject to some very limited exceptions. While the First Amendment does not apply to private employers, public employees enjoy full constitutional free speech protections in their government workplace. 

Obviously, an authoritarian regime like the Empire would not extend free speech rights to anyone, including the regime’s employees. But if Prauf had been an employee of a more democratic governmental agency or other public employers, disciplinary retaliation against him for expressing his views would violate fundamental constitutional rights.

Raising concerns about workplace safety

Other than constitutional free speech protections, alternative sources of labor law could have protected Prauf’s challenge to the working conditions at the Bracca scrapyards. For example, Prauf’s remarks about employees’ expendability and about workers being “worked” may be construed as complaints about the hazardous working conditions faced by scrappers, particularly in light of his earlier peril and Cal’s improvident heroics. 

The federal Occupational Safety and Health Act protects employees from employer retaliation for engaging in protected activities under that statute. Specifically, OHSA prohibits employers from discharging or discriminating against employees who have filed complaints or have testified in OHSA-related investigations. 29 U.S.C. § 660(c)(1). This protection extends to employees who express concerns to management about occupational safety. 29 C.F.R. § 1977.9(c); see Marshall v. Springville Poultry Farm, Inc., 445 F. Supp. 2 (M.D. Pa. 1977) (adopting Labor Department’s regulatory interpretation that complaint to employer is protected activity for purposes of § 660(c)(1)). Thus, if Prauf were in any condition to do so after his termination, he could certainly file a complaint with the Department of Labor, which could then seek a remedy on his behalf for the employer’s retaliatory conduct in violation of OSHA.

“Mutual aid and protection”

Additionally, the recent Rise of the Resistance novel, which takes place decades after the events in Jedi: Fallen Order, tells us that the workers of Bracca’s scrapyards are unionized by the Bracca Guild of Scrappers, Union Local 476. But it seems unlikely that the Empire would permit workers to organize, so the Bracca workforce was probably not unionized at the time of Prauf’s speech. 

In any event, the National Labor Relations Act protects the right of workers at both unionized and non-unionized private workplaces to engage in “concerted activity . . . for mutual aid and protection.” 29 U.S.C. § 157. This provision of the NLRA does not require current union representation of the employee and covers a broad range of activities that are focused on improving collective terms and conditions of employment. See, e.g., Modern Motors v. NLRB, 198 F.2d 925, 926 (8th Cir. 1952). Importantly, the NLRA does not protect an individual’s expression of a personal complaint about an employer, even if the complaint is addressed to a group of fellow employees, unless the evidence suggests that the speaker intended the complaint to inspire others to organize the workforce to improve working conditions. Mushroom Transp. Co. v. NLRB, 330 F.2d 683, 685 (3d Cir. 1964) (recognizing that preliminary discussions may amount to concerted activity if the speaker intended group action as a consequence).

Here, the employer would likely argue that Prauf’s speech to his coworkers about their poor treatment was not intended to inspire collective action, but was rather intended as a smokescreen to distract the Inquisitors from their search for Cal. While Cal would personally consider Prauf’s conduct as “aid and protection,” it may be a stretch to characterize this as a preliminary discussion of organizing their workforce.

On the other hand, Prauf could argue that the Inquisitor’s intimidation of the scrappers was the final straw that inspired him to speak up and assert their collective rights on behalf of the group: “But we all know the truth. We’re just too afraid to say it. To the Empire… we’re all just expendable.” 

Prauf’s termination is just the first step in Cal’s heroic journey, but finding the courage to speak up and resist oppressive conditions is at the center of all Star Wars stories. Prauf embodies the same heroism you would expect of any Jedi… and in a way that is a bit more relatable to all of us working stiffs here on Earth.

The Disintegration Defense

0

Jawas: Disgusting creatures who a certain golden protocol droid can’t abide.  C-3PO’s opinion of Jawa cleanliness aside, their reputation as enterprising scavengers is legendary in the galaxy far far away.  However, Jawas don’t always acquire their treasured junk in strictly the most legal of ways.  In the second episode of The Mandalorian, the Mandalorian learns firsthand about the Jawas’ preferred procurement method: Brazen theft.

After securing the cutest bounty in the galaxy, our intrepid…hero?…makes the long trek back to his ship, the Razor Crest, only to find it being ransacked and stripped clean by a group of Jawas.  With his only ride off the planet being disassembled before his very eyes, the Mandalorian does what any well-adjusted member of a galactic warrior race would do: He opens fire with his rifle, disintegrating several of the diminutive thieves.

Despite being one of the funniest scenes in recent Star Wars history, could the Mandalorian resort to deadly force to protect his ship?

Darth Vader should have ABSOLUTELY allowed disintegrations in The Empire Strikes Back.

At first glance, the Mandalorian seemingly has a compelling case for opening fire on the Jawas.  He’s on a dangerous planet escorting a relatively defenseless baby and suddenly finds himself outnumbered by the Jawas, who are clearly armed and in the middle of committing a brazen crime.

But under the law you unfortunately can’t just disintegrate your way out of all your problems.  When it comes to using deadly force, the law is especially restrictive, limiting the circumstances in which you can kill another person.  These rules are in place for a good reason, since we don’t want armed citizens running around acting like Han Solo in the Mos Eisley Cantina.

Virtually every state in the U.S. allows the use force to protect yourself or another person.  However, given the high value placed on human life, the use deadly force is considered a last resort.  For example, in Pennsylvania, you may use deadly force to defend yourself or another if you reasonably believe that such force is necessary to prevent great bodily harm or death.  That reasonable belief requirement sets an intentionally high bar for using deadly force.

Here, even though the Mandalorian was heavily outnumbered and had a small (adorable) alien baby in tow, he wouldn’t be able to convincingly argue that he disintegrated in self-defense.  Before opening fire, he was a good distance from the Jawas to the point that he needed to use a scope to see what they were up to.  While some of the Jawas may have been armed, they carried short range ion weapons and were not firing towards him.  In fact, the Jawas don’t make any threatening moves toward the Mandalorian until he starts his disintegration spree.  It’s therefore going to be nearly impossible for the Mandalorian to claim some form of self-defense to justify his actions.

The Mandalorian graciously went straight Oprah on the local Jawa clan.

But what about defending the Razor Crest?  It’s clear that the Mandalorian isn’t vaporizing poor Jawas because he thinks he’s in danger, he does it in order to protect his ship.  On it’s face, this reaction seems rational.  After all, he manages to catch the Jawas in the act of stealing a large amount of his property, including items from within his ship and large chunks of the ship itself.  More importantly, the Razor Crest is his only way off the dangerous planet.  Given those factors, shouldn’t he be able to protect it at all costs?

Although those are seemingly compelling reasons to use deadly force, the Mandalorian is stepping into some serious legal poodoo by doing so.  While the law recognizes the inherent value in defending life, the idea of hurting or killing another person over a piece of property simply isn’t acceptable or legal in most places.  In fact, only Texas law allows the use of deadly force to protect tangible movable property.  That means that in 49 out of 50 states, it wouldn’t matter how valuable or important the Razor Crest is—disintegrating Jawas to protect it would not be a justified killing.

Even if Arvala-7, the planet shown in episode 2, uses a version of Texas law (which, given what we’ve seen of the planet, isn’t so far-fetched), the Mandalorian would still be in hot water.  Despite its permissive nature, Texas law still has restrictions on the use of deadly force to defend property.  Although Texas law allows the use of deadly force to prevent the commission of a theft, it requires that the theft be at nighttime.  That fact might seem like a minor technicality, but it’s an important limiting factor in the statute.  While I’m no expert in the planetary day/night cycle of Arvala-7, the Mandalorian confronts the Jawas in broad daylight.  That means not even the law of the great state of Texas will protect the Mandalorian in this scenario.

All judges shall henceforth be required to work this quote into all hearings and trials.

Given the Mandalorian’s serious legal predicament, he can only hope that he gets a judge like C-3PO, whose disdain for Jawas clearly outweighs his commitment to law and order. Alternatively, the New Republic could rally around a change in the law, making for deadly force to defend property, so long as it is done hilariously by way of disintegration.

When Jawas Attack

0

It is one thing to scavenge and another to steal someone’s personal property. In The Mandalorian episodes The Child, a group of Jawas in a Sandcrawler were caught stripping the Razer Crest for parts. Multiple issues explode out of this incident.

Grand Theft Jawas

The Razer Crest was the personal property of The Mandalorian. The vehicle was parked on the planet Arvala-7. The Jawas worked collectively to strip the Razer Crest of parts, its outer hull, engine parts, equipment, and the Mandalorian’s weapons locker.

Grand theft is when a person takes real or personal property of another with a value over $950 or when property is taken from an automobile. Cal. Pen. Code § 487(a) and (d)(1). While the interstellar exchange on Beskar is unknown, the value of the Razer Crest and the equipment onboard is easily over $950 in value. The Jawas committed Grand Theft with their stripping and pillaging of the ship, which understandably upset the Mandalorian.

Trading With Jawas for the Return of Stolen Property

The Jawas wanted to “trade” something of value in exchange for the parts to the Razer Crest. Normal contract negotiations include an offer, terms, acceptance, consideration, and performance. This is rather insulting when the trade is for the return of personal property. This raises the issue of economic duress, which is when “a wrongful act which is sufficiently coercive to cause a reasonably prudent person faced with no reasonable alternative to succumb to the perpetrator’s pressure.” Andrieu v. Aquantia Corp., H044638, at *13-14 (Cal. Ct. App. Nov. 21, 2018). Moreover, a party can rescind a contract if consent was “obtained through duress, menace, fraud, or undue influence.” CA Civ. Code § 1689(b)(1). Furthermore, statutory duress is when there is the unlawful detention of a person’s property.  CA Civ. Code § 1569.

The Jawas demanding the Mandalorian to retrieve “The Egg” from a vicious wild animal in order to recover his personal property meets every meaning of “duress” in contract law. The Jawas found bold new ways to benefit from their lawless behavior, the most extreme in making someone risk their life for breakfast.

Adventures in Babysitting 

The Mandalorian took his infant Target on a mission to storm the Jawas’ high speed Sandcrawler and on the worst egg hunt imaginable. This is in addition to fighting off Trandoshans and a gunfight with Jawas. Has the Mandalorian engaged in child endangerment?

California defines child endangerment as the following:

Any person who, under circumstances or conditions likely to produce great bodily harm or death, willfully causes or permits any child to suffer, or inflicts thereon unjustifiable physical pain or mental suffering, or having the care or custody of any child, willfully causes or permits the person or health of that child to be injured, or willfully causes or permits that child to be placed in a situation where his or her person or health is endangered, shall be punished by imprisonment in a county jail not exceeding one year, or in the state prison for two, four, or six years.

Cal. Pen. Code § 273a(a).

Whether there has been child endangerment is highly fact specific. The Target’s bassinet following the Mandalorian while he attempted to board the Sandcrawler could have produced “great bodily harm” if the Jawas had fired upon the bassinet. The Jawas also deployed more medieval countermeasures of throwing objects at the Mandalorian, which could have caused injury if directed at the Target. However, since the bassinet was out of the line of fire from the bassinet, one can argue it was safer for the bassinet to follow the Mandalorian instead of being left alone in the desert.

The Mandalorian made the least dangerous decision by taking the Target with him to secure the Egg. Given the options to recover the parts were either leave the Target with Kuiil, who was with the Jawas who had expressed interest in the Target, the Mandalorian would have been rightfully concerned for the Target’s safety in the event more bounty hunters attacked or the Jawas turned on Kuiil. While leaving the Target to the side while confronting a large animal was not Plan A, it was the least bad option available to the Mandalorian.

A Public Policy Shootout over Contracts in The Mandalorian

0

Long, long, ago, in a courthouse far away, it was said that the freedom of contract be not lightly interfered with. Baltimore Ohio c. Railway v. Voigt, 176 U.S. 498, 504-5 (1900). The Mandalorian is a story with parties entering contracts upon contracts. However, what contracts in the first episode were valid and which were not?

The Enforceability of an Oral Contract Entered During a Shootout

The Mandalorian met IG-11 while the droid started an armed assault on a compound holding the Target for their respective bounties. This created an awkward meeting, as the Bounty Hunters’ Creed states that No Hunter Shall Interfere With Another’s Hunt. The Mandalorian made the offer that they split the reward for capturing the Target, to which IG-11 agreed. What was not agreed upon was IG-11’s counter offer to acquire the Reputation Credits for the hunt.

The basics of contract formation are 1) Offer; 2) Acceptance; 3) Consideration; and 4) Performance. Moreover, “All persons are capable of contracting, except minors, persons of unsound mind, and persons deprived of civil rights.” Cal. Civ. Code § 1556. Furthermore, the question for California courts is whether there is mutual assent between the parties, which is “manifested by an offer communicated to the offeree and an acceptance communicated to the offeror.” Donovan v. RRL Corp., 26 Cal.4th 261, 270-71 (Cal. 2001), citing 1 Witkin, Summary of Cal. Law (9th ed. 1987) Contracts, § 128, p. 153.

From the context of the shootout, the Mandalorian made an offer for he and IG-11 to work together and split the reward. IG-11 accepted this offer verbally and by conduct. However, there was no mutual assent on the issue of IG-11 getting the Reputation Credits for the hunt. While that term was not agreed upon, a court could find there was a contract between the parties to split the profit from the hunt.

IG-11’s Bounty Claim Violated Public Policy

Whoever contracted with IG-11 to kill the Target violated public policy and the Bounty Hunter’s Creed. The Mandalorian was right to take protective measures against IG-11.

The Bounty Hunters’ Creed states that:

In the Hunt One Captures or Kills, Never Both

In cases where the acquisition had been taken alive, that “choice” could not be altered. To kill an acquisition in the course of the hunt was one thing, but to purposely kill an unarmed, helpless being already subdued and unable to resist was seen as simple slaughter and wanton butchery. An acquisition “killed while attempting to escape” however, would be an entirely different matter altogether.

The Mandalorian had a contract to capture the Target; IG-11 had a contract to kill the target. IG-11’s contract to purposely kill an unarmed and helpless being was a gross violation of the Bounty Hunters’ Creed. Whoever hired IG-11 did not want a Bounty Hunter, they wanted a butcher.

A contract to kill someone is not the work of a bail bondsman, but a murder-for-hire contract. It is grossly illegal to contract to kill someone, especially an infant. The legal term is solicitation. Anyone who solicits another to commit murder can be sentenced to state prison for at least three and up to nine years. CA Penal Code § 653f. This raises significant issues as to what kind of puck was issued with a kill order on an infant, the work of a bail bondsmen is to bring someone in, not play hit man.

Contracts cannot violate public policy, which was defined by Lord Brougham, “that no one can lawfully do anything which has a tendency to be injurious to the public welfare.” Maryland C. Co. v. Fidelity Etc. Co., 71 Cal.App. 492, 496-97 (Cal. Ct. App. 1925). A contract is void against public policy if it “clearly contravenes that which has been declared by statutory enactment or by judicial decisions to be public policy, or unless the agreement manifestly tends in some way to injure the public.” Spangenberg v. Spangenberg, 19 Cal.App. 439, 446-47 (Cal. Ct. App. 1912). As murder is clearly defined as being illegal and against public policy, one cannot enter a contract to murder another person.

I Have Spoken 

Can Bounty Hunters Use Lethal Force?

0

The Mandalorian is the story of a bounty hunter in the Outer Rim who is no stranger to using lethal force. Is it lawful for a bounty hunter to kill?

As a preliminary matter, many states have stopped using the term “bounty hunter.” In California, such as individual is a “bail fugitive recovery person,” who has extensive statutory requirements, including having both bail and private investigator licenses. CA Penal Code § 1299.02. Other requirements include having proper documentation before apprehending a bail fugitive; must not represent themselves as being with law enforcement; and provide at least six hours of notice to local law enforcement that they are going to apprehend a bail fugitive, absent exigent circumstances. CA Penal Code §§ 1299.05; 1299.06; 1299.07; and1299.08.

There are two big requirements: bail fugitive recovery persons cannot forcibly enter a premise or carry a weapon unless in compliance with state laws. CA Penal Code §§ 1299.09 and 1299.10.

In arguendo that the Mandalorian was in compliance with California gun laws, could a bounty hunter shoot a bail jumper? In a Connecticut case that asked whether warning shots could be fired at a fleeing bail jumper, the answer is “no.” The Court explained, “A bounty hunter’s legal right to seize and hold does not automatically authorize the use of force…” McGibony v. Danaher, No. CV094020419S, 2009 Conn. Super. LEXIS 2609, at *7 (Super. Ct. Oct. 1, 2009).

That is not the end of the analysis. In the first episode of The Mandalorian, there was a fight with a human and a Quarren. The elements of the confrontation include the Mandalorian entering the cantina, not saying anything, and walking up to the bar. The two assailants surround the Mandalorian with claims the Mandalorian spilled the human’s drink when the Mandalorian entered the cantina. The human struck his knife across the Mandalorian’s chest armor and asked if the armor was real Beskar. This contact is technically battery, because the contact was a “willful and unlawful use of force or violence upon the person of another.” Cal. Pen. Code § 242.

The contact of the knife against the armor was the moment the Mandalorian responded to the physical battery upon his person. This triggered classic self-defense analysis. The Mandalorian could have reasonably believed he was in immediate danger of being killed or suffering great bodily harm, because he was surrounded and a knife had made contact with his person; The Mandalorian reasonably believed the use of force was needed to defend himself; and the Mandalorian used no more force than was necessary to defend against the danger. The human assailant was subdued with the use of force, but lethal force was not used on the Quarren until he fired a blaster at the Mandalorian. See, 1 CALCRIM 505 (2018). All of the Mandalorian’s actions were proportional to the threats he faced during the altercation.

Now, we don’t exactly know what Sub Paragraph 16 of the Boadsmen’s Guild Protocol Waiver says exactly, but it is hard to imagine that giving IG-11 a license to storm a stronghold by force…

Mandalorian Podcast on Chapter 1

0

The Mandalorian is here and Gabby Martin, Thomas Harper, and I sat down to discuss the first episode of this awesome series. Can bounty hunters kill bail jumpers? When a contract is unenforceable because it violates public policy? Find out as explore these issues and all want a toy from the big shocker at the end of the episode.