The People of the State of New York, Respondent v. Joseph Kress, Appellant

Summary

The New York Court of Appeals reversed Joseph Kress's robbery conviction and remanded for a new trial because the State failed to provide the independent corroboration required by Code Crim. Proc. § 399. The majority held that the two pieces of evidence offered – the alleged $100 payment and the mechanic's testimony about a speedboat trip – were insufficient. A dissent argued that the evidence was adequate and the conviction should be affirmed.