Embezzlement is not a Recent Phenomenon; Dr. Robert Kyle, Los Angeles Dentist, victim in 1942 of $550 steal

Embezzlement from dental practices is not a recent development. In 1942, Los Angeles dentist Dr. Robert Kyle pursued criminal charges against his dental assistant after she diverted $550 from his practice — a case that produced a documented California (CA) appellate opinion and stands today as one of the earliest recorded instances of dental embezzlement in the American legal record.

Dr. Kyle's assistant was responsible for, among her other duties, receiving and recording patient payments. The complaint alleged that she collected payments and failed to account for them, pocketing cash that should have gone into the practice's records. She was tried, convicted on two counts of grand theft, and subsequently appealed both the verdict and the denial of her motion for a new trial. The California Court of Appeal rejected the appeal. Writing for the panel, Judge McComb cited the rule that evidence must be viewed in the light most favorable to the prosecution, found the evidence sufficient to sustain both convictions, and affirmed the judgment of the trial court.

The case is a reminder that the fundamental vulnerabilities facing dental practices — employees in positions of trust with access to cash and patient payments — have existed for as long as the profession itself.