This chapter portrays the American Catholic defense of sacramental confession, that part of the Catholic penitential tradition that was under the most severe criticism in nineteenth-century America. The Catholic apologetic, begun during the People v. Phillips court case, continued during the entire nineteenth century in polemical tracts, dogmatic manuals, parish missions, broadsides, parish sermons, newspapers, and episcopal conciliar statements. The Catholic apologetic took four different forms that justified sacramental confession, emphasizing the biblical, doctrinal, and theological foundations; the beneficial moral, social, and political consequences; the spiritual and psychological blessings; and the primitive Christian historical origins. By the end of the nineteenth century, though, a few Catholic priests were beginning to criticize some of the confessional practices that had developed during the nineteenth century.