In Baldonado v. California (1960), the U.S Supreme Court upheld a decision by the California District Court of Appeal, which had convicted Manuel Baldonado for burglary. The case revolved around whether or not evidence obtained through an allegedly illegal search and seizure could be used in court against him. The police officers who arrested Baldonado did so without a warrant after they saw him acting suspiciously near the scene of a recent burglary; during his arrest, they found stolen goods on his person that were later used as evidence to convict him. In its ruling, the Supreme Court held that since there was probable cause for arresting Baldonado due to his suspicious behavior at night in close proximity to where burglaries had occurred recently, it was reasonable for them to conduct a search incident upon arrest without needing a warrant first.

In the dissenting opinion for Baldonado v. California, Justice Hugo Black argued that the petitioner's constitutional rights were violated when he was not allowed to cross-examine a key witness against him. The case involved a murder charge where an accomplice's confession implicating Baldonado was used as evidence in court, but this accomplice did not testify at trial and thus could not be questioned by Baldonado’s defense team. According to Black, this denied the defendant his Sixth Amendment right "to be confronted with the witnesses against him." He believed that using such confessions without giving defendants an opportunity to challenge their veracity undermines confidence in verdicts and is fundamentally unfair. Furthermore, he noted that it contradicts previous Supreme Court rulings which emphasized the importance of cross-examination in ensuring fair trials. Therefore, he dissented from the majority ruling upholding Baldonado's conviction.