Law & Order: SVU season 26 episode 17 recap — does Carisi get justice?
Deonte finally goes on trial for the robbery case.

In Law & Order: SVU season 26 episode 17, “Accomplice Liability,” Carisi (Peter Scanavino) is on pins and needles as it’s time for Deonte’s (Keith Machekanyanga) case to go to trial. Carisi is haunted by the robbery that took place that day in the deli, and is hoping to get justice in court so he can start to put this whole ordeal behind him. However, he ironically becomes a stumbling block in that happening.
Additionally, Tess (Paige Herschell), the young woman who was sexually assaulted by Deonte’s accomplice Boyd (Silas Weir Mitchell), has unraveled in the months after the ordeal and is in no condition to testify. However, SVU rushes to help her regain her power and her life. But is Olivia’s (Mariska Hargitay) team successful? And does Carisi get justice?
Here’s what happened in Law & Order: SVU season 26 episode 17.
Where is Tess?
Carisi and Rollins (Kelli Giddish) arrive at ADA Camille Rourke’s (Stacey Farber) office to talk about the case, as she’ll be the prosecutor. He asks the attorney about the deal she’s offering Deonte — 15 years for felony murder in the second degree of the deli clerk, plus a few years for armed robbery. Perplexed, Carisi wonders about other charges like felony assault and rape for what happened to Tess, as Carisi believes Deonte is liable. Rourke says the ADA who transferred her the case noted it was the “weakest” charge. Carisi is livid and storms out.
In the SVU squad room, the team hasn’t had any luck finding Tess, who has been missing for a week. Elizabeth (Tori Khalil), Tess’ friend who was with her during the robbery, also hasn’t heard from Tess as they had a “falling-out.” Olivia tells an agitated Carisi that she and Rollins will go to Elizabeth's job to talk to her.
Rourke meets with Deonte and his attorney, who are unhappy with the deal. Deonte claims Carisi told him it would be self-defense if he shot Boyd. She scoffs that Deonte shouldn't be surprised that an attorney lied to him during a hostage situation and claims that if he rejects the deal and they go to trial, he could go to prison for life.
At Elizabeth’s preschool, she says the last time she met with Tess, things didn’t go that well, accusing Tess of stealing her laptop and self-medicating to deal with her mental anguish. Olivia asks if she has a tracker on it, which Elizabeth confirms she does. The computer was last tracked to a sketchy block in Jersey. SVU flocks to a home in Jersey and finds Tess in the midst of a drug overdose.
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Tess and Carisi have setbacks during the trial
At the hospital, the doctor tells Olivia and Rollins that Tess is stable but out of it as they are detoxing her system. The detectives go into Tess’ room, and the young woman is agitated, wanting to return to the home in Jersey and to be left alone. Ollivia and Rollins leave and meet Velasco (Octavio Pisano) and Fin (Ice-T) in the hallway. Olivia says an officer has to be placed outside of Tess’ room to ensure she doesn’t flee. Velasco volunteers.
Olivia and Rollins update Carisi on Tess. He tells them he has to go to court as the defense wants to exclude his testimony. During the hearing, the defense argues that with Carisi being a prominent ADA, his testimony can be prejudicial to the jury. The prosecutor argues that it's ridiculous, as he is the victim. The judge ultimately sides with the prosecutor.
Back at the hospital, Tess suffers a setback, seizing and losing consciousness. Doctors manage to get her stable and inform Olivia that Tess has likely gotten through the hardest part in her recovery.
Carisi meets with Rourke, begging her to talk to Tess as he desperately wants her to add a rape charge against Deonte. Rourke agrees as long as Carisi backs off and lets her prosecute the case as she sees fit. She then tells him the defense believes he has a personal vendetta against Deonte; Carisi admits he may. Carisi keeps thinking about the guns used in the robbery. Boyd had just gotten out of prison a few hours before the robbery and was likely incapable of getting his hands on the weapons. Carisi suspects Deonte brought the guns into the mix, and so everything that happened is his fault.
Finally stabilized, Tess is ready to leave the hospital. Having been encouraged by Olivia and Rollins, Tess is willing to testify about being assaulted the day of the robbery. Velasco escorts her to a hotel that the NYPD is putting her in for the duration of the trial.
During the trial, the defense does a great job of painting the picture that Deonte was never the one in charge during the robbery and was likely under duress by Boyd. Then, when it’s time for Tess to testify, she goes missing again. Velasco doesn’t find her in the hotel and SVU doesn’t find her at the Jersey home. The detectives learn of another place where Tess sometimes goes to score drugs, and they find her hiding in a closet. Despite wanting to use again, she didn’t, but is scared to testify. Velasco and Fin offer her the support she needs to take the witness stand, which she does tearfully.
Carisi is next to take the stand, saying what Deonte did wasn’t self-defense but self-preservation. The defense attorney then presses all of Carisi’s buttons during cross-examination. When Carisi steps off the witness stand, he spots Deonte smiling, causing Carisi to explode at him in open court. Outside of the courtroom, the DA scolds Carisi for what he did. Amanda comforts Carisi, and he believes they have to find a way to get into Deonte’s head since Deonte got into his.
Rollins and Fin find a smoking gun against Deonte
Rollins and Fin meet with a fake lawyer who is awaiting trial for murder, who happened to be Deonte’s associate in prison. They get him to give them intel on Deonte. The man says Deonte told him the real reason he shot Boyd.
Deonte takes the witness stand and says he was afraid of Boyd and under duress, which is why he went along with the plan. When Rourke starts questioning him, she asks where Boyd got the guns, which makes Deonte noticeably uncomfortable. The prosecutor then questions if Boyd was in the cooler with Tess for 40 minutes, assaulting her, why wouldn’t Deonte just walk outside and let the police into the deli if he was so afraid of Boyd? After all, Boyd wasn’t around. Deonte doesn’t respond.
Rourke calls her final witness to the stand, the man Rollins and Fin met with. He testifies that the only reason Deonte killed Boyd was so Boyd couldn’t testify against him. Deonte looks horrified by the remarks.
Deonte is found guilty of murder and armed robbery, but he’s found not guilty on the rape charge. In the hallway, Tess claims to be okay that as she was at least able to testify.
New episodes of Law and Order: SVU air on Thursdays on NBC and become available the next day on Peacock.
Terrell Smith has a diverse writing background having penned material for a wide array of clients including the federal government and Bravo television personalities. When he’s not writing as Terrell, he’s writing under his pseudonym Tavion Scott, creating scripts for his audio drama podcasts. Terrell is a huge fan of great storytelling when it comes to television and film. Some of his favorite shows include Abbot Elementary, Matlock, The Lincoln Lawyer, Survival of the Thickest, The Pitt and Godfather of Harlem. And a fun fact is he's completely dialed into Bravo Universe and The Young and the Restless (thanks to his grandmother).
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