In the season 9 finale "Cold", Novak violates due process by violating the Brady rules while prosecuting a corrupt police officer who raped two 14-year-old illegal immigrants, killing one. Donnelly, now a judge, calls Novak into her chambers and informs her that the DA had declined to refile charges against the defendant because of her actions. Donnelly informs Novak that she is facing censure by the Bar and a suspension of her license to practice law for at least a year.