Gotham season 3, episode 14, " Mad City: The Gentle Art of Making Enemies ," features the return of Jerome Valeska, who engages in a chaotic showdown with Bruce Wayne at a circus. This pivotal episode highlights Bruce defining his moral code by refusing to kill Jerome during a dramatic confrontation in a hall of mirrors. Additionally, the episode showcases Edward Nygma's betrayal of Penguin, leading to a major turning point in their relationship and a shocking final reveal involving the Court of Owls.