The University of Texas at Austin

Law in Popular Culture collection

Legal Studies Forum
Volume 12, Number 3 (1988)
reprinted by permission Legal Studies Forum

FROM PERRY MASON TO KURT WALDHEIM: THE PURSUIT
OF JUSTICE IN CONTEMPORARY FILM AND TELEVISION

DAVID P. LEONARD
Indiana University School of Law - Indianapolis

     For the post-war generation, the late 1960's began a period of grow-
ing disillusionment about and suspicion toward traditional American in-
stitutions. This loss of confidence is reflected strongly in attitudes toward
the system of justice and the lawyers and judges who are its officers.
Fueled by evidence of fundamental injustice in the nation and adventur-
ism abroad, the post-war generation began to question the moral under-
pinnings of the justice system. This questioning occurred despite the
teaching to which that generation had been exposed, which held that the
American system of justice was the single institution which most clearly
evidenced the moral superiority of American institutions. Though history
had revealed isolated instances of injustice, we were taught that those
occasions arose not from the failings of the system's judges and lawyers,
whose labors were approached with almost missionary zeal, but from
causes outside the system itself. Only the warped talents of those rare
people of true evil could render the system impotent to achieve truth and
justice. Two clear lessons emerged from this traditional teaching: the sys-
tem itself was pure, and the system was capable of finding underlying
truths in the cases that were channeled through it. The events of the past
twenty years have created fundamental uncertainty about the truth of
these lessons.
     The depiction of the system of justice in American cinema and televi-
sion has reflected this loss of confidence. Though counter-examples can of
course be cited, it can be said generally that prior to the late 1960's, media
presentations of the justice system were largely uncritical. They evi-
denced little ambivalence about the system's integrity or its ability to root
out and identify evil. In recent years, however, growing doubt about the

[377]

purity of the system itself, and the concomitant sense that the system is
incapable of reaching acceptable findings of right and wrong, have begun
to consume cinematic and television treatments of the justice system. This
essay will examine this change in the depiction of the legal system. After
exploring this theme, the essay will conclude with speculation about an
even more troubling possibility: that our doubts about the integrity of the
system shelter a deeper societal uneasiness about whether there is truly a
clear line between good and evil.1
     Prior to the past two decades, film and television portrayals of the law
generally placed the system of justice itself in the background. It was not a
character, but a silent, dependable partner in the inexorable process of
uncovering truth. Perhaps nowhere was this benign and reassuring depic-
tion of the legal system more evident than in the "Perry Mason" series,
which ran for nearly a decade from the mid1950's to the mid-1960's, and
which has been recently reactivated in the form of occasional television
movies. Each episode represented a successful search for truth, culmina-
ting in the identification of evil and the exoneration of the wrongly accused
defendant. At the end of each program, the audience experienced
(perhaps intuitively) a strong sense of reassurance that the lawyer's skill
can be used to uncover truth. The integrity and constancy of the system of
justice were never in doubt; all actors in that system were committed to
learning the truth. Even the ever-embattled prosecutor, whose theory al-
ways proved flawed, never viewed himself as the loser. He was, instead, a
satisfied actor in a system designed to find truth, and he knew that he
played an essential role in the process of achieving justice.
     Events of the past two decades have shaken deeply our faith in the
integrity and competence of the system of justice, and the media of film
and television have played an important role in highlighting this change in
attitude and focusing the deep concerns that change represents. From
1972 to 1974, our televisions brought into our homes undeniable evi-
dence of corruption at the uppermost levels of government, reaching not
only into the political system but also into the Department of Justice it-
self. Though rough justice was ultimately achieved when the President
was driven from office and his highest officials convicted and disgraced,
we could not escape the fear that what we had witnessed on television was
but a symptom of a deeper illness, that the very system which we had been
raised to believe set our nation apart was itself rotting away.

[378]

     As real-life events have taken away our nnocence about the integrity
of the system of justice and the lawyers and judges who are sworn to
uphold it, the film and television media have begun to present images that
reflect our sense of unease. The examples are many and dramatic.
     In the 1987 release "Suspect," Cher plays a Washington, D.C. public
defender worn down by a system in which she feels herself merely an
insignificant part. She is looking forward to a vacation and, perhaps, a
reassessment of her career. But she loses her opportunity for such a break
when she is assigned to defend a deaf, homeless man accused of commit-
ting a brutal murder. There are at least two ways to view what follows.
The first is to see the plot as a relatively engaging thriller which becomes
compelling because of the audience's identification with Cher's character
and its curiosity about the plot's resolution. At first, we identify with
Cher's fear as she tries to penetrate the man's violent, antisocial exterior
and establish some communication with him. When she succeeds in
breaking through, and becomes convinced of the man's innocence, we are
drawn in by Cher's attempt to find proof of the man's innocence and of
the true killer's identity. When Cher is approached by Dennis Quaid as a
juror in the trial who is himself skeptical of the defendant's guilt, she
knows that mere communication with this person is an ethical violation
for which she may lose her license to practice. Yet compelled by her
attraction to Quaid's character, by her desire to help her client, and by her
growing sense that something is terribly amiss, Cher begins to work with
the juror to solve the crime, and we go along. The same is true as Cher,
now physically endangered, reaches closer to the logical but surprising
conclusion. The story is highly improbable. That description, however,
characterizes most films in this genre, and the lapses here are no greater
than usual.
     A second way to view "Suspect" is to examine more deeply the mean-
ing of its major events. Under its surface, the plot reveals a much darker
set of truths. The more we examine Cher's triumph, the more we realize
that it is triumph despite, rather than within, the system. The true killer,
after all, was not a faceless psychotic but the very judge who was presiding
over the case, a man who had orchestrated both the murder and the subse-
quent prosecution in order to prevent his own corrupt past from being
revealed. The one person in whom we depended most deeply to affirm

[379]

our values about the system of justice, who in fact personifies that system,
serves not just as an unwitting impediment to the discovery of truth (as we
were led to believe throughout much of the story), but as the very agent
of evil. And the only way in which Cher is able to piece together the
diverse clues to uncover the truth is to move outside the constraints of the
system of legal ethics by establishing contact with the juror, a Washington
lobbyist of questionable morals who would bed a congresswoman in order
to obtain a favorable vote for a client. So while the truth may be revealed
in the end, Cher's victory is at best an ambivalent one. We come away
somewhat reassured that good can prevail, but despite rather than because
of the system. Indeed, the character most personifying the system itself is
utterly corrupt, and Cher's strict adherence to the constraints which the
system would place on her conduct would have prevented her from un-
covering the facts which led to the identity of the killer and the exonera-
tion of her client.
     The 1985 film "Jagged Edge" explores somewhat similar themes.
There, Glenn Close plays a lawyer hired to defend Jeff Bridges, who has
been charged with the brutal murders of his wife and maid. As with "Sus-
pect," the film can be viewed on at least two levels. Superficially, it is a
relatively well-constructed mystery, with the lawyer quickly deciding that
the client is innocent and beginning to search for clues to the true crimi-
nal's identity. That the lawyer falls in love with her client only increases her
zeal to discover the truth. She does a good job; her client is acquitted, and
all seems well. But after the trial, the lawyer accidentally uncovers a key
piece of evidence proving conclusively that her client was in fact guilty.
When the client learns that his lawyer has uncovered the truth, he tries to
kill her. But she is prepared, and kills him.
     On a deeper level, "Jagged Edge" also explores the frailty of the
criminal justice system and the ability of some people to undermine its
truth-determination function. Early in the story, we learn that Close's
character had once been an assistant prosecutor in the district attorney's
office, working for the man who has now risen to the position of District
Attorney and who is prosecuting her client. On one occasion while Close
was an assistant prosecutor, she handled a case on which her boss unethi-
cally suppressed evidence which would have exculpated the defendant.
Close got a conviction, and the man was sent to prison where he was

[380]

murdered. Close feels enormous guilt over her complicity in this matter,
and the underlying tension created by her remorse for her past misdeed
and her extreme dislike for this prosecutor seriously clouds Close's judg-
ment. Consumed by this emotion, and led astray by her client's mock
sincerity, she ignores the prosecutor's warnings of her client's evil and
becomes an unwitting participant in the undermining of the system.
Though the guilty client pays his dues in the end, it is not the system itself
that has brought him down. It is his own lawyer, acting independently,
after the system has failed. Once again, serious questions have been raised
about the possibility of achieving justice through our formal institutions.2
     In the 1987 film "Nuts," Barbra Streisand plays the middle-aged
daughter of wealthy parents. The character has suffered severe emotional
problems which have caused the breakup of her marriage and led her to
become a prostitute. One day, she kills a customer. The audience is shown
in unequivocal terms that the character acted in self defense; her customer
had become extremely violent, and posed a clear and immediate threat to
her life. But agents of the criminal justice system are unaware of these
facts. Finding the woman's behavior aggressive and uncooperative, the
state begins proceedings to have her declared mentally incompetent and
institutionalized rather than brought to trial for the killing. The woman's
parents, convinced that she is insane and believing that institutionalization
represents her only hope for regaining a normal life, become eager parti-
cipants in this proceeding. As the audience knows, however, Streisand's
character is not crazy, and the remainder of the film consists of her efforts,
supported by lawyer Richard Dreyfuss, to prove herself competent to
stand trial. When she triumphs in the end, it is not because of the mental
health and justice systems, but despite them. Her victory has been
achieved by a fight over, rather than in cooperation with, the system.
     Dennis Quaid, whose morally ambiguous juror in "Suspect" was of
central importance in solving the crime, played a similar character in
another 1987 film, "The Big Easy." Here, Quaid is a New Orleans police
officer, following a long family tradition. The department is highly cor-
rupt, and Quaid is as deeply involved as the other policemen and detec-
tives. He willingly accepts his cut of bribe money paid by crime figures,
and plays along in other corrupt practices. Ellen Barkin is a government
attorney, called in from outside New Orleans to conduct a murder inves-

[381]

tigation. She possesses little knowledge of the depth of the system's cor-
ruption, and shows no understanding or toleration when that corruption
begins to be revealed to her. The more she learns of the system, the more
debased she believes it to be. But her investigation leads nowhere until
she somewhat unwillingly accepts Quaid's help. Disgusted by his methods
but drawn by his personal charm and intimate knowledge of both the
system and the criminal world, Barkin begins to make progress, and ulti-
mately solves the crime. But she has done so only by dealing with the very
corruption which she so abhors. Toward the end of the story, when Bar-
kin is drawn to a Cajun community where Quaid teaches her a local dance
step, it is more than to a new kind of music that she is learning to move.
She is also learning to dance with a system she despises but knows she
must work with in order to do her job. It may be true that at the conclu-
sion of the story, Quaid stops participating in the system's corrupt prac-
tices. But he does so at great cost, and we are left with the sense that the
debasement of the justice system is very deep indeed. Any hope that the
system may be purified must be tempered by that realization.
     Many of these themes have been reinforced in the television series
"L.A. Law." In this program, the legal system is often portrayed as
bureaucratized and unwieldy to such a degree that if truth emerges, it is
only because persistent lawyers (often dragging demoralized clients be-
hind them) have the tenacity to keep fighting. In these depictions, the
system is constantly shackled by detail, its actors unable to capture the
larger meaning of cases absent the heroic efforts of lawyers who simply
will not concede. And at times, it is the system itself which comes under
attack.
     In one of the more challenging "L.A. Law" plots, lawyer Anne
Kelsey, played by Jill Eikenberry, represents a psychiatrist in a civil action
brought by the parents of a murdered woman who was one of his patients.
One of the psychiatrist's other patients had allegedly carried a machete
into the psychiatrist's office and told him that he was going to use it to kill
the woman. The psychiatrist fails to warn the patient of the threat, and the
woman is killed. The machete-wielding patient pleads guilty to the crime,
and is imprisoned. In the course of the civil trial, however, Kelsey becom-
es suspicious of the credibility of the confessed killer, who has been called
as a witness. Kelsey manages to create sufficient doubt in the minds of the

[382]

jurors about whether the man actually killed the woman that the jury
refuses to hold the psychiatrist liable for failing to predict the man's vio-
lent behavior. After the trial, Kelsey tells the psychiatrist that she believes
the real killer is still loose, and seeks his help to track the killer down. The
psychiatrist then tells Kelsey that it was he who killed the woman because
the woman had threatened to reveal that they had had an affair. The
psychiatrist reminds Kelsey that he has just divulged confidential informa-
tion in the context of the attorney-client relationship, and that she will
face disbarment if she reveals that information.
     Kelsey is apparently disabled by the very system she has sworn to
uphold. She is told that she cannot reveal what she knows, but she is
aware that unless that information comes to light, an innocent man will
remain in prison, the victim's family will continue to be deprived of any
compensation from the man who in fact committed the murder, and the
killer will remain free. For Kelsey, as well as for the audience, it is not just
the killer who prevents justice from being done, but the system of justice
itself. In the show, a rough form of justice is ultimately achieved when the
fact of the psychiatrist's guilt is "unethically" leaked to the newspapers by
an ill, aging attorney who has little to lose. This act will almost certainly
end the psychiatrist's career, and may even make his prosecution possible.
But the doing of justice has occurred outside the system, not within it. We
are told to accept that there is no route within the justice system by which
this guilty man can be punished and the innocent man exonerated.
     Several episodes later, Kelsey once again faces an ethical dilemma
when defending a company accused of creating severe health risks by pol-
luting a body of water. When she learns of the client's actual responsibil-
ity, and of its indifference to the human consequences of its actions, she
blackmails the client into making payments far beyond those which it
would otherwise have had to make. Once again, the achievement of jus-
tice has required Kelsey to abandon her institutional role as representa-
tive of a client, and to become its adversary. But unless Kelsey takes these
actions, we believe, true justice will not be done.3
     If the bureaucratization of the legal system is a nuisance in many
"L.A. Law" plots, it is the very subject of Terry Gilliam's 1985 "Brazil."
In this desolate portrait of the near future, law and justice are no
longer merely impeded by an unwieldy bureaucracy, they have become

[383]

bureaucracy. Indeed, we see no lawyers or judges at all; every public func-
tion is handled by countless individually insignificant bureaucrats. Impor-
tant tasks have been divided into such minuscule pieces that none of these
tiny actors has any perception of the ultimate effects of his or her actions.
When a dead insect drops into a machine as it is printing the name of a
man who is to be arrested, a single character in the spelling of the name is
accidentally changed. That the information on the paper may be inaccu-
rate is of no concern to the authorities charged with apprehending the
man, for it is the performance of the arrest - itself a bureaucratic act -
which is important, not the facts which might have given rise to the deci-
sion to arrest. Here, in contrast to most other films and television pro-
grams, justice does not prevail. In the end, the man is indeed apprehended,
and tortured to death. It is no wonder that the studio for which the film
was made was so reluctant to release the movie. Gilliam was only able to
cajole the studio into releasing the film by purchasing a full-page ad in a
trade journal begging, in essence, that the studio let his film be seen. The
Los Angeles film critics immediately voted "Brazil" the best picture of the
year.
     There is much to be learned from the change in the media's depiction
of lawyers in recent years. These films and television programs show us a
society fundamentally in doubt about the honor of its most valued institu-
tions, and this is deeply troubling. But there may be an even more dis-
turbing truth beneath the surface of our loss of confidence in the system
of justice, and this truth, too, may be reflected in the media of film and
television. The possibility is this: that in addition to our growing doubt
about the ability of our system to root out evil, we are also beginning to
doubt that there is a clear distinction between good and evil themselves.
     This troubling possibility was not reflected in earlier media presenta-
tions of the justice system, which were largely positivist. Perry Mason's in-
evitable victories affirmed not only the strength and competence of the sys-
tem but also the bright line between right and wrong, between good and
evil. The show justified our faith in these beliefs each time we watched,
and thus our knowledge that Perry Mason would always win compelled
rather than bored us. Like Michelangelo, who held that the pure sculp-
ture already existed inside the rocks on which he worked, we accepted
that truth was clear and could be revealed if only we possessed the skill

[384]

and determination. Observing Perry Mason at work in his own artistic
context reaffirmed our faith in the existence of the truth inside the rock.
     Even today, reruns of the old episodes are highly successful in syn-
dication, and the several television movies which have brought the charac-
ter back to life have found large audiences. At the same time, the popular-
ity of such "reality" programs as "People's Court" has been extraordinary.
Manifestly, a part of our collective selves still yearns to believe in clear
truth, and in the basic wisdom and competence of the system. Though we
no longer possess the sense of innocence and trust that underlies the con-
ception of the legal system in these shows, we still want to be able to
believe in that image of the system. We want to suspend, even if only
temporarily, our disillusionment. Through these characterizations, we
find a kind of satisfaction that our sense of reality does not permit.
     This is not to suggest that the post-war generation is the first to have
suffered a sense of loss and disillusionment. Undeniably, the generation
which came of age in the 1920's and 1930's bore witness to the most
illusion-shattering period of human history. After the revelations of the
Nazis' atrocities, it was difficult to believe fully in the essential goodness
of all people. The impact of this experience on the sensibilities of the
pre-war generation cannot be minimized, but the disillusion which accom-
panied these horrible revelations was of a different type. Though the rev-
elation of the atrocities of World War II cost our society its innocence, it
did so at that time precisely by exposing the undeniable malevolence of
certain forces in the world. The world contained far more evil than could
previously have been imagined, but the evil was identifiable and clear, or
so it seemed. And our need to be able to continue to see this evil embo-
died in particular individuals and institutions made it possible for figures
such as Senator Joseph McCarthy to rise to prominence. Above all else,
the promise he held out was the very identification of evil, and we
accepted his efforts with gratitude until his own excesses were themselves
revealed.
     By the time the post-war generation reached adulthood, however,
the division of the world into forces of good and evil was no longer quite
as easy. Perhaps certain totalitarian regimes had committed unspeakable
atrocities, but when the hands of the democratic powers were examined,
they too were found unclean. How could the world's democracies have

[385]

refused to accept desperate refugees from murderous regimes? How
could our own nation's military have been deeply segregated along racial
lines? And how could the United States have been the only nation ever to
have used the ultimate weapon of destruction against the population of
another nation, even though a sworn enemy? Although there are rational
responses to each of these questions, the point is that the very need to
face such issues creates enormous uncertainty about the moral superiority
of our institutions and the line between good and evil, both of which we
had been taught to take for granted.
     A recent Home Box Office presentation provides perhaps the most
subtle but fullest realization of this phenomenon. In the lengthy produc-
tion "Waldheim: A Commission of Inquiry," an international panel of
judges is convened to hear evidence presented by two distinguished
lawyers on the question of "whether there is sufficient evidence to war-
rant an answer by Dr. Kurt Waldheirn to allegations that he wrongly par-
ticipated in acts which were contrary to the international laws of war"
while a soldier with the German army in World War II. This was not a
dramatic presentation in the usual sense. It was a film culled from forty
hours of presentation of testimony and documentary evidence in an
adversarial context, followed by six weeks of deliberation by the panel of
judges. There were no "actors" in the program. The judges were actual
current or former judges representing five nations, and the lawyers pre-
senting the evidence for each side were seasoned trial counsel.4 Though
obviously carrying no legal authority for its proceeding, and though made
in the absence and without the cooperation the inquiry's subject, the com-
mission's purpose was to try to determine, in a dispassionate, formal con-
text, whether there is sufficient evidence to bring Waldheim to trial.
     It was an ambitious undertaking. Its unstated goal, no doubt, was to
help the audience to come to a clearer understanding of the nature of
good and evil. No one asserted that Kurt Waldheim wielded the weapons
which murdered innocent people or personally placed screaming women
and children into crematoria. Most of those responsible for committing
such acts, or for directly and knowingly ordering that such acts be carried
out, have long since been brought to justice. But at the same time, neither
the counsel presenting the evidence against Waldheim nor the man whose
job it was to challenge the evidence doubted that Waldheim was a part of

[386]

a machine which engaged in the most brutal and wide ranging crimes in
the history of the world. It is easy to imagine that the filmmakers hoped
that even in this era of increasing uncertainty about the difference be-
tween good and evil, the proceeding, and the program to be made from it,
would reveal a bright-line distinction. Allan A. Ryan, Jr., who presented
the evidence against Waldheim, recognized the underlying moral ques-
tion involved, and argued eloquently for a clear resolution:
To reach a fair conclusion, this Commission must consider the
nature of responsibility for war crimes.... We have seen not
isolated individual crimes, but a continuing criminal enterprise.
And so, this Commission should not be lured into a search for
the one officer responsible for each of these crimes. It will not
find him, for that officer does not exist. And if it goes off on such
a futile search, this Commission would fall precisely into the trap
set by the array of unrepentant witnesses who came before this
Commission.... You see what they are doing. They are inviting
you to search for the tiny black pinhead of malignancy that is
responsible for all the cancer. Do not be misled. History and the
evidence show us Nazi-crimes poisoned the entire system....
For two years, Kurt Waldhelm has been urging the world to do
what Nazis have done since 1945 - to slice the responsibility
into such tiny pieces that no one can be held responsible....
     [Shall Kurt Waldheim be made to answer for his acts,] or
shall he be let go, the allegations dismissed because he was, after
all, just a lieutenant, a lieutenant who did his job? All of them
did their jobs. The greatest crime of our time would not have
happened except for that.
     The Commission listened to the evidence, deliberated at length, and
determined that the evidence was insufficient to warrant an answer by
Waldheim. As viewers, we can understand why this result was reached,
but we are most ambivalent. We watched the show in hope of reaffirma-
tion that good and evil are clearly distinct, and that the system can root
out evil once presented with the evidence. We believed that this type of
formal tribunal, the very embodiment of our system's greatest strengths,
could make things more clear. But it could not. If we cannot clearly dis-
tinguish among those who should be held responsible for the most mas-

[387]

sive and inhuman crimes ever committed, there cannot be great hope that
such distinctions can easily be drawn by our justice system in handling the
day-to-day cases with which it is faced. The program held a mirror before
our eyes, but we could not see more clearly.

[388]

Notes

1. Though similar changes can perhaps be found in other genres such 
as war and police stories, the essay will for the most part limit its 
discussion to those films and television programs in which lawyers and 
judges are the central characters.

2. "Jagged Edge," of course, is not the first film to portray a 
devious client who leads his lawyer, and the system, astray. In the 
classic 1958 drama "Witness for the Prosecution," murder 
defendant Tyrone Power outwits both his lawyer Charles Laughton 
and the jury. But the plot gives us no strong reason for disillusionment 
with the system itself.

3. Not all recent films have played fair in their characterizations of 
the failings of the legal system. Two films in particular, "The Verdict" 
(1982) and "The Star Chamber" (1983) have grossly distorted and 
exaggerated these failings. The thesis of "The Verdict" appears to 
be that the civil justice system is so corrupt that neither side stands a
chance without engaging in unethical conduct. The story is presented 
not as satire but as an accurate portrayal of the way lawyers work, 
and as such it is deeply flawed and unjustifiably cynical. The same 
comments apply to "The Star Chamber," a film which implies that 
large numbers of violent criminals must be released because of legal 
technicalities. The film trivializes the constitutional underpinnings 
of these "technicalities" and, like "The Verdict," is especially troubling 
because of its effort to convince the audience that it presents an 
accurate portrayal of the system.

4. In the sense that this program was unscripted, and that the 
filmmakers controlled neither the evidence presented nor the 
outcome of the inquiry, the film is different from each of the others 
discussed in this essay. This type of work does not as clearly
represent the point of view of the filmmakers. In some ways, 
though, the film provides an even clearer picture of a society in 
the act of debating its most fundamental moral terms. The judges 
are being asked to determine the nature of moral responsibility,
and this process is being preserved on film.