In Netflix’s The Lincoln Lawyer, Sam Scales is ultimately killed on the orders of Alex Gazarian, who has him “whacked” and uses the murder to frame Mickey Haller for the crime.

Gazarian, a mob-connected businessman involved in a shady biofuel/BioGreen- style scam, discovers that Sam has been skimming money from their operation and decides to eliminate him. Sam’s body is then planted in the trunk of Mickey’s Lincoln, triggering the central mystery and Mickey’s arrest, until the Season 4 finale reveals that Gazarian was the one who ordered the hit, with other mobsters later killing Gazarian himself when the heat from Sam’s murder becomes too intense.