The apparent negative crack growth phenomenon which usually arises in partial unloading compliance test is well known. The reason for apparent negative crack growth is the compressive residual stress caused by the plastic zone around the crack tip. The phenomenon as a possible source of error in determining $J_{JC}$ or J-R curve from partial unloading compliance experiments may be eliminated by the correction of compliance. A compliance correction equation is derived from a stress field analysis near the crack tip.