New York Court of Appeals
The People of the State of New York v. . Henry J. Jaehne
October 5, 1886103 N.Y. 182
Summary
The New York Court of Appeals affirmed the conviction of Henry J. Jaehne for bribery, holding that section 72 of the Penal Code applies to municipal officers and supersedes section 58 of the Consolidation Act. The Court reasoned that the Penal Code, as a later general statute, repeals the earlier local provision and that a confession corroborated by surrounding circumstances satisfies the statutory requirement for conviction. A dissent by Justice Rapallo argued that the Consolidation Act should control and that the judgment must be reversed and a new trial ordered.