User blog comment:Retro Elite/PE Proposal: Devil Ray/@comment-30634893-20190721230313

Pretty easy no. While he is vile, he utterly fails to compare to the standards set by many other worse DCAU villains; especially considering that he only appeared in a measly two episodes. Murder really isn't as uncommon as one would think in the DCAU--many Batman: TAS and Batman Beyond villains, obviously including the Joker, have done it a few times, and in far more brutal fashions that Devil Ray's killing of some of the monks and Deadman's mentor, so they fail to genuinely stick out (I mean, he wasn't even the only villain ruthlessly gunning down the monks there). Plus, the act of killing someone who is a close personal friend of the hero in the story has been done before in the DCAU too, and in far worse manners as well; for example, Darkseid's killing of Dan Turpin.

So, yeah. I don't think he's quite PE.