While it’s interesting that NCIS wants to keep revisiting the past murder committed by its hero, Leroy Jethro Gibbs (he was avenging the killing of his family). However, each time they do it the result is the same — he never pays. But there was another NCIS character who wasn’t as lucky.
It happened at the end of Season 5 on the hit CBS show. Then-NCIS director, Jenny Shepard (Lauren Holly), realized an old op was going to cause trouble — it had already gotten another agent killed and she knew that either she or Gibbs (Mark Harmon) could be next.
The two-part season finale was called Judgment Day — and as Jenny tried to save Gibbs (she already had a death sentence — a fatal diagnosis she’d kept hidden from everyone but Ducky), he used that same time to try to figure out if she had murdered arms dealer René Benoit.
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You see, Shepard blamed Benoit for the murder of the person most important to her — her beloved father, Colonel Jasper Shepard. So obsessed with his suicide that she believed was murder, she had a five-point plan, which included her rise at NCIS until she had the power to get him.
It looked like Gibbs did find the evidence that proved Shepard had killed Benoit several months earlier. At the end of the first episode of the two-parter, Shepard died of her wounds after killing the men sent to kill her. Shortly after, her phone shows Gibbs calling, probably to confront her.
So while Jenny was dying for him, Gibbs was looking for the proof she murdered a man whom she believed killed her father. So in Judgment Day, we’re to assume that judgment was served — Jenny died for her crime — the exact crime Gibbs also committed but manages to get away with every time the show revisits it.
On last night’s episode, the rogue judge (played by M*A*S*H star Mike Farrell) wanted Gibbs to pay for committing murder with his life (the judge couldn’t get the irony even when Gibbs explained it) but other than having to tell his team, it was the judge who ended up paying — not Gibbs.