Modern Family’s Sarah Hyland was one of the best guest stars in Law & Order: SVU history. Here’s why.

Photo: NBC
Over its many years of airing, Law & Order: Special Victims Unit has welcomed notable guest stars ranging from Robin Williams to Sarah Paulson. However, one performance still stands out in fans’ minds above all: a young, pre-Modern Family Sarah Hyland.
The actress has actually appeared on the show twice, the first time in 2001 for the season three premiere, “Repression,” and then during season 10 in episode 12, “Hothouse.” It is a true testament to her talent that her latter appearance aired back in 2009 and is still being praised despite the series now going into its 26th season.
The episode is about the death of a teenage mathematics prodigy named Elsa whose body is found in the Hudson River. While the team originally thought the murder was tied to sex trafficking, it ended up being a case that actually exposed the toxic and deeply unsettling methods students use to achieve academic success at an academy.
Hyland portrays Jennifer Banks, Elsa’s roommate and “loyal best friend.” When Olivia Benson (Mariska Hargitay) and Elliot Stabler (Christopher Meloni) go to talk to her early in the episode, she points them in the direction of Elsa’s parents, specifically her father, and also paints Elsa as someone else entirely. A little over halfway through, they quickly realize Elsa really hated Jennifer and there was real tension between the two over being the smartest.
After over 200 episodes, Hyland is best recognized for playing Haley in Modern Family, which is obviously a comedy. However, this role allowed the actress to show just how excellent she was in a drama. From obsessively worrying over a chess tournament she has the following week to stressing about the need to come out on top when it comes to the competition, she perfectly presents how a student (and teen) can only be pushed so far before they snap completely. It’s a lesson that still needs to be addressed today.
In the interrogation room, while admitting that she is the one who killed Elsa after following her onto the ferry, Jennifer has a full breakdown, screaming all of the details of the fight out until she just gives a small sob. This scene and monologue alone, which can only be ended with an “I’m number one now, mom. Aren’t you happy for me?” is the reason Hyland is remembered as one of the greatest guest stars in Law & Order history.
Naturally, both detectives push for her to get put into a place where she can get some real help since she is clearly very troubled and only 14 years old. Unfortunately, Elsa’s body was pushed into the river just off of Hoboken, making it a New Jersey case, where they try kids her age as adults and send them to prison for life. Benson and Stabler are called as witnesses during the trial, but the entire time, you don’t want to take your eyes off of Jennifer, who cannot stop fidgeting and looks extremely panicked until the judge announces the case will be heard in adult court. A “game over” sets her off again, comparing this to chess and yelling “Be smarter, be better, fight harder. The best isn’t good enough” as she stands on the table before getting carried out to a jail cell.
She then asks Benson repeatedly why she’s there and the detective calmly explains that she killed Elsa, leading to the younger girl saying that nothing makes sense, adding “It’s all blank and I’m trapped in this horrible endgame of a chess match that I don’t remember sitting down to play.” Another disturbing confession comes after when Jennifer mentions that she never sleeps thanks to Provigil. It turns out that the school has been telling students how to trick their doctors into prescribing these drugs to help them focus. She had been up a total of six days before the murder and currently has been up three days.
After finding new evidence and finding out more information, Benson manages to convince the defense to give a plea agreement that includes Jennifer being remanded to juvie for a period not to exceed seven years. This gives her a chance to turn her life around when she gets out.
Fingers crossed that Hyland decides to make another appearance on the series in the future but until then, you can rewatch both of her episodes on Peacock in the U.S.
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