I read Batman #422 last night and said I’m shocked that I’ve only seen a couple panels from it, because this is absolutely essential context for the Garzonas incident. I promised a long explanation so…here it is.
TL;DR: Shortly before the Garzonas incident, Jason takes part in another case involving a rapist escaping justice because of legal technicalities. The only way that rapist is stopped is through murder. Jason is also shown acting uncharacteristically in response to this case.
There are these two men, Branneck and Vito, who are kidnapping women, raping and mutilating them, and then throwing their corpses in dumpsters. By the time Batman figures them out and loops Jason in on the case, they have killed eleven women. Branneck kills Vito and attempts to flee, but Batman catches him and procures evidence.
But Batman procured this evidence illegally, and Branneck has a good lawyer. The judge throws the evidence out, and Branneck walks away.
Immediately afterwards, Jason finds an abusive pimp and beats him to the point where Bruce questions if Jason was trying to kill him. Jason expresses that it wouldn’t have actually been that bad if he did. You’ve probably seen these panels floating around before:
In context, though, this is not normal for Jason. This is his direct reaction to their previous case, where a murderer and rapist is allowed to go free.
This is establishing not just Jason’s reaction to cases involving sexual violence, but Jason’s reaction to justice unserved. This is the first case that I’ve seen Jaybin take involving rape or a villain who the law can’t touch. Maybe he’s reacting to the sexual violence. Maybe he’s reacting to the injustice. Maybe he’s reacting to both. But whatever the reason, this specific combination of circumstances really gets to him. Now, if I had a nickel for every time Jaybin watched a rapist escape the law despite everyone knowing he’s guilty, I’d have two nickels—and it’s important that it happened twice.
Later, Branneck chooses his next victim. She’s actually the sister of his second victim, and she tracked him down. When he tries to kidnap her, she kills him. This killing is part vengeance, part self-defense, and part necessity.
Bruce doesn’t think it was right. Jason does. But Bruce does admit that part of him wishes he didn’t have to operate within the legal system.
Jason and Bruce have discussed the morality of killing multiple times in post-crisis so far, and this isn’t the first time they’ve had this discussion. Jason has, from the beginning (of post-crisis), expressed an acceptance towards killing. Bruce has expressed…conflicting thoughts. He doesn’t kill, except he has killed in self defense. But then he locks KGBeast underground to die. Even when telling Jason they don’t kill, he states that he still wants some people dead, or that it wouldn’t be a loss if they died. So, this discussion isn’t unusual.
But the circumstances take this debate very close to the Garzonas situation.
So, a few things happened here:
This case in particular ignites an uncharacteristically violent reaction in Jason. He seeks out another perpetrator of sexual violence and takes his anger out on them.
Jason watches a murderer and rapist walk free and then attempt to commit his crimes again. This man is only stopped through death, and if Judy hadn’t sought him out and killed him, another woman would be dead.
Batman and Robin could not have saved that victim. If Judy hadn’t existed, someone else would have died and Branneck would’ve left the city. They were truly powerless.
Jason reiterates that he thinks killing can be right, including in the specific scenario of stopping a rapist who the law can’t touch. Bruce states his disagreement, but is conflicted.
When it comes to Garzonas, Jason has all the pieces in Batman #422. He has the anger. He has the philosophy. He has the drive. And he has the template—all that’s left is him taking Judy’s place and stopping the rapist before he hurts anyone else.
And this is important whether you think Jason killed Garzonas or not.
Because if Jason killed Garzonas, well, this comic is pretty much an explanation, a justification, and foreshadowing—all rolled into one. And if Jason didn’t, this at least explains why Bruce was so quick to believe he did—and why Jason may have considered it.
Now, I personally think Jason killed Garzonas, and that this comic offers further evidence for it. Because after watching this case, it’s a pretty reasonable conclusion that Garzonas needs to be dead. Jason could easily apply what he learned from the Branneck case—the only way to stop a monster who can't be legally prosecuted is death—to the Garzonas case. This also establishes Jason's strong reaction—because of the timing (maybe Bruce is right and he's finally processing his parents' deaths), because of the sexual violence (to my knowledge this is the first time Jason has encountered an extended case involving sexual violence), or because of the injustice of it all (because before, it was simple, and Jason could trust that when Batman and Robin caught the bad guy, they'd go to jail, even if it took some effort).
But regardless of your belief about that scene, this comic two comics before the Garzonas incident is absolutely essential background information. Because after Branneck, it's a pretty reasonable conclusion that there was nothing Jason could do to save Garzonas's future victims other than kill him. This case is a wakeup call, a proposed solution, and a nudge towards the edge, all rolled into one.