In Pennington v. United States (1913), the Supreme Court dealt with a case involving an individual, Mr. Pennington, who was convicted of perjury in relation to his testimony given during a bankruptcy proceeding. The main issue at hand was whether or not the lower court had erred by instructing the jury that they could find him guilty based on contradictory evidence provided by two witnesses alone, without any additional corroborating evidence supporting their testimonies. The Supreme Court held that this instruction was incorrect and reversed Pennington's conviction. The court stated that under federal law, for someone to be found guilty of perjury there must be more than just contradicting statements from two individuals; there must also be independent corroborative evidence which supports one side over another - essentially proving beyond reasonable doubt that perjury has occurred. This ruling clarified how courts should handle cases where conflicting witness testimonies are presented as primary evidences in charges of perjury.

In the dissenting opinion for Pennington v. United States, Justice Holmes argued that there was insufficient evidence to prove that Pennington had committed perjury. He contended that the majority's decision relied too heavily on circumstantial evidence and failed to consider other plausible explanations for inconsistencies in Pennington's testimony. Furthermore, he criticized the court for not providing a clear standard of proof in perjury cases, which could potentially lead to wrongful convictions based on weak or ambiguous evidence. In his view, convicting someone of perjury should require more than just showing they made inconsistent statements under oath; it should also be necessary to demonstrate beyond reasonable doubt that these inconsistencies were deliberate lies rather than honest mistakes or misunderstandings.