July 19 2024

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Review: CSI: Miami — ‘Habeas Corpse’

10 min read

Ryan becomes the main suspect when a crooked ASA winds up dead, in the season ten finale of CSI: Miami.


Ryan regains consciousness with a bloody nose, and he looks over to see that ASA Josh Avery is dead on the floor beside him. He came here to talk to Josh about using his girlfriend Sam to tamper with evidence in an investigation, but they got into a fight. Ryan was knocked out, and he doesn’t know who killed Josh. Unfortunately, he can’t prove his innocence, so the team must treat him as a suspect. When Calleigh maps out the trajectory of the blood drops in the room, she discovers a line of cast-off from the murder weapon, which is a broken wine bottle. There’s a void in the line, which matches a set of droplets on the back of Ryan’s jacket. He was lying on the floor, unconscious, when Josh was murdered. He has been exonerated, so he puts on some gloves and gets to work on the case.

Walter and Ryan discover a bug in the phone, and they suspect that Darren Vogel is responsible. However, Dave discovers something troubling: the bug belongs to the MDPD. Sam planted it the day before in an attempt to catch her lying boyfriend in the act of conspiring with Vogel. She did get a recording, but the team can’t use it as evidence because it was obtained using an illegal wire tap. Horatio takes Sam off the case, and she cleans out her locker in anger. Ryan asks for any information she can give him about Josh, and she reveals that he owns a boat. They dated for two years, but he never took Sam out on it. She wondered if that was where he kept his secrets.

Tripp and Natalia head out to the boat, but someone on board opens fire, killing the man who was leading the way. The two cops rush for cover, and Natalia is able to take out the shooter. When they head onto the boat, they discover a large quantity of meth. Ryan and Eric test the drugs, determining that they belonged to Eddie Coster, who was arrested two years ago. He was not convicted thanks to his attorney, Darren Vogel, but his drugs were seized. Ryan heads into the evidence vault with Walter to check the drugs, but the quantity is all accounted for—until Ryan realizes the drugs were switched with bags of flour. They assume that Josh Avery is responsible, but it’s Sam’s name on the record as the person who logged the evidence when she worked the night shift two years ago.

Ryan tries to call Sam, but she doesn’t answer her phone. She’s been taken hostage by Eddie, who is forcing her to drive at knife-point while Vogel sits in the backseat. Eddie is angry, claiming that they all tried to make a profit from his hard work, and Vogel is unable to reason with him. The police are trying to follow the car, but Sam runs off a bridge and crashes to the ground below. They take her to the hospital with a broken ankle, and Ryan takes her shoes. He finds a piece of broken glass in the tread, which matches the glass from the crime scene. She’s the one who killed Josh.


The opening minutes of “Habeas Corpse” hook you immediately with the sight of Ryan, bleeding and confused next to a dead body. The scene is cut with flashbacks to the night before, when Ryan joined Walter, Natalia and Eric for drinks while they discussed crooked ASA Josh Avery. His tampering ruined their case against one of Darren Vogel’s clients, and Ryan is angry that he used his girlfriend Sam to gain access to the lab. Natalia is quick to point out the obvious: if Sam’s boyfriend tampered with evidence on her watch, every case she has ever worked will be called into question. Natalia doesn’t know that Sam has walked up, but she doesn’t back down when Sam confronts her and asks if Natalia thinks she’s dirty. Natalia says that, at the very least, dating Josh Avery for two years indicates that she has bad taste in men. Ryan walks away, claiming he has better things to do with his time, and Sam calls Natalia a bitch before following him.

Ryan is on a mission, and Sam knows exactly where he’s going. He wants to confront Josh, apparently assuming that a talking-to from a CSI will make the man turn himself in. Ryan is clearly trying to protect Sam, even though she asks him not to, but things don’t go quite as planned. When we see the flashbacks showing the confrontation between Ryan and Josh, the difference in their stature seems exaggerated. Ryan looks tiny compared to Josh, who towers over him and refuses to back down. He tries to suggest that Sam is the one who tampered with evidence, but Ryan doesn’t believe him. He throws the first punch, but Josh hits him back several times and knocks him out.

Luckily, Ryan is exonerated quickly. Sam works better as an episode-long suspect, and it’s not entirely surprising that she’s the one who killed Josh. Sam has been a big recurring character for most of the season, making her a familiar face, although there has never been much of a connection with the rest of the team. Ryan has a crush on her, of course, and she has formed friendships with several other members of the team. I would have liked some sort of reference to her history with Walter during “Habeas Corpse”. After all, they worked together on the night shift before he joined the day shift to become a CSI, and he was her first friend when she joined the day shift as well. I’m disappointed that we never saw much of their friendship during Sam’s time on the show. Meanwhile, she and Natalia have always had a prickly relationship, which is highlighted at the beginning of the hour. After Josh is murdered, the women stand beside each other in the lab and watch as Ryan is being processed. Natalia offers her condolences for Josh’s death, and she reminds Sam that Ryan was only there because of her. Sam told him not to go, and she says the whole thing spiraled out of control. Natalia has to leave after a minute, unable to continue watching while her friend is treated like a suspect.

Ryan’s crush on Sam has been ill-fated from the start, and he made a romantic overture in the form of a thoughtful gift (“Friendly Fire”) before finding out that she was already in a relationship. There was still a flirtation and obvious attraction between them, and Ryan feels betrayed when he figures out that Sam may be involved this week. He goes out of his way to protect her, but in the end, he has to confront her about killing Josh. He comes to see her in the hospital, sitting beside the bed and waiting for a moment before he broaches the subject. She finally tells the whole story, explaining that she came over and demanded to know what happened when she saw Ryan on the floor. Josh got physical with her, so she hit him with the wine bottle in self-defense. When she realized he was dead, she panicked and ran away.

Ryan is devastated that she kept the truth from him, and that she left him in the apartment. He has done nothing but defend her, but she didn’t trust him enough to tell him what happened. Sam apologizes for letting Ryan down, and Ryan says that he’s sorry too. Jonathan Togo does a wonderful job of showing just how hurt Ryan is by how this all turned out, and Taylor Cole turns in a really good performance in the hospital scene as Sam struggles with her actions and the way she has hurt Ryan.

At the end of the hour, Ryan meets up with Walter, Tripp and Dr Tom Loman. The scene is similar to the one at the beginning, showing the team members sharing a drink off the clock. Ryan is lamenting that he will be alone forever, and the others try to comfort him. Walter points out that it might be best to date someone he doesn’t work with, and Tom suggests that he give online dating a try. After all, he met his girlfriend Lulu in a science chat room. The others have never heard of her, and they’re shocked when he pulls out a photo of himself with a beautiful woman. Their reactions are hilarious, and they’re still laughing when Eric and Natalia arrive. Natalia seeks to reassure Ryan by pointing out that he is a smart, funny, good-looking man, and he responds that he’ll ‘take you right now on the table.’ They all laugh, and Natalia quips that they could use the Hummer instead. Ryan then points out that one thing he has going for himself is his full head of hair, which is clearly meant to tease poor Tripp, and Ryan apologizes and kisses the man’s bald head while the others laugh. Eric takes a serious tone for a minute, reminding Ryan that he will never be alone because the team is his family. They all love him, and that point is emphasized when team dad Horatio arrives to share a drink—as long as Ryan is buying. It’s a fun, light-hearted way to end the season, and it’s a fitting end to the series should CBS decide not to pick Miami up for an eleventh season.

The only one missing from the final scene is Calleigh, who has spent the hour trying to finish the process of adopting Austin North and his little sister Patty. The agency is worried that she is a single woman with a dangerous, time-consuming job, and they need to know that she can provide for the children if they are put in her care. She has no choice but to leave when she gets called to the Josh Avery murder scene, and she worries that it reflects badly on her. She confides in Eric that she doesn’t think she’s the best option for the children, and she admits that there’s another family being considered—a traditional family with a more stable home life. Eric is loyal, encouraging her not to give up, and he heads to the agency later in the day to serve as a character witness. He tells the adoption supervisors that Calleigh is a great woman who will make a wonderful mother, and he points out that she won’t be raising those children alone. She has created a strong, close-knit family group at the lab, and they will all be there to help her through the ups and downs of taking care of two children. In the end, Eric’s words help to sway the agency in Calleigh’s favor, and she is given custody of the children as the hour draws to a close. She’s beaming with happiness, and she starts to get emotional when the children come in to hug their new mother. She gives Eric a call to thank him, and he reminds her that she’s got a lot of loving family members to stand beside her as she makes this transition.

Becoming a mother is a big step, and it will have a major effect on Calleigh’s life and career going forward. “Habeas Corpse” alludes to Calleigh’s past (and perhaps future) romance with Eric, but there are no overt gestures to suggest that they will be getting back together any time soon. Eric shows how much he cares about her, but he never makes those promises as a lover, only as a friend and colleague. He doesn’t say he’s going to help her personally, he refers to their entire work family as one unit. I think it’s a good choice, allowing for the possibility that they could get back together without making it too quick and impulsive. If the show comes back for another year, the relationship could be developed over the course of the season. Calleigh is a mother now, and the dynamic between her and Eric will have to change to accommodate this new role in her life.

One character we may not see back in the family next season is Natalia, since Eva La Rue has been cast in an ABC comedy pilot. If the pilot goes to series, La Rue will stay on board, but she still has the option of returning to Miami if things with the new series don’t work out. Natalia has become one of my favorite characters on the show, and season eleven just wouldn’t be the same without her. I would really miss La Rue if she left, but I wish her the best in her career.

The show’s future remains uncertain, so I’m not surprised that the writers altered the way the season was supposed to end. Early reports indicated that the finale arc would center around the infamous Navarro family, and that the team would be torn apart. With the show on the bubble, it’s good that they decided to end on a high note with the team reaffirming their family ties, rather than having the season end with the family in tatters. As a season-ending cliffhanger, it would have worked, but it would have been disappointing as a series-ending moment. I hope the show will be back in the fall, but we won’t know for sure until CBS makes the announcement within the next few months. I’ve grown quite attached to the entire CSI franchise, so I would love to see at least one more year with all three series on the air.

See also: “Habeas Corpse” episode guide

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12 thoughts on “Review: CSI: Miami — ‘Habeas Corpse’

  1. The only thing that I didn’t think was right about this episode is that they let Ryan right back into the investigation after they proved he was lying on the floor with the blood on his back, etc. Any good Defense lawyer would throw this case out in court regarding the evidence. How would we know Ryan didn’t have an accomplice or something? It was too quickly to put him back in the case. But anyway, I’m just thinking too much. Love the episode! 😀

  2. wasnt that “ernie”from the 70s my three sons at the adoption agency/?

  3. I absolutely LOOOOOOOVED the episode sooooooo! Im just so freakinglad they FINALLY got rid of sam. I knew right from the start she was up to no good. I was NOT surprised they let ryan off the hook and back in the in to the investigation. The ONLY part that I didnt like was in the hospital room ryan told her she was there in the room and she killed josh, she right away blamed ryan sayng “if you had just listen to me this would’ve happened”. Yeah when you kill the assitant state attorney blame somebody else, let them take the fall…NOT! In the beginning ryan was defending sam but, like ALWAYS he ended up getting hurt in the end. OUTSTANDING EPISODE!!! All in all let me say one thing, “SAM IS GONE”!!! Im over the moon happy. Ryan can definately do much better.

  4. Yep, Barry Livingston played one of the adoption supervisors, and he was on My Three Sons during the 1960s-70s.

  5. i love nick out of csi i allway wacth the old csi and i have a mate who love the new and the old csi love you nick xxxxxx

  6. In case anyone is wondering, the show was cancelled. Good thing they didn’t leave us hanging.

  7. I was saddened to hear and see it has ended. Luckily here in the UK, with regards Miami we are way behind America. Vegas we are only about 6 weeks behind, New York we are only about 3 weeks behind.

  8. i loved Sam from the very begening!!!!11! why do so many peopl h8 her? If u guyz knew her backstory y’all woud NOT b judgin. if ANY OF U noticed episode 13, shes wearing half of a locket and NO NAIL POLISH. the reason the writers did this was 2 express sorow emptyness and the childhod she NEVAR had. H8rs gonna h8 4 lyfe!!!!!1111!11!

  9. Wow! It’s just a show! Any of us who watched the show knew her back story, it’s part of the show. Just where did we learn she had a difficult childhood? Maybe I blanked out then, as she was so irritating and bland. (I am not a “h8er” just didn’t care for her character or her acting.) So she had no nail polish? Just what is that supposed to signify? I thought she was an irritating no-it-all from the first episode she was in. All the interaction between her and the others was negative from her part. She was uppity. She was rude. She did call Natalia a *itch! And after all, she was a murderess!

    By the way, Samantha wasn’t even in episode 13!

    One thing I absolutely hate in shows, when they use the same actor in a series, playing different parts. The actress in question here played a different character a few years earlier.

  10. Oops, meant “Know-it-all” of course! I do “know” the difference! And I wouldn’t be using “text speak” on a forum, unlike the Swine Flu!

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