In the Baldwin v. Alabama case of 1984, the United States Supreme Court ruled on a matter concerning state taxation and interstate commerce. The appellant, Baldwin, was an out-of-state corporation that sold goods to customers in Alabama but did not maintain any property or employees within the state itself. However, Alabama imposed a franchise tax on Baldwin based on its total worldwide capital rather than just its business activity within the state. The Supreme Court held that this method of taxation violated both Due Process Clause and Commerce Clause of U.S Constitution because it failed to provide a fair apportionment related to intrastate values and activities. Therefore, taxing an out-of-state company's entire net worth when only part of their business operations occurred in Alabama was deemed unconstitutional.

In the dissenting opinion for Baldwin v. Alabama, Justice Brennan disagreed with the majority's decision to uphold Alabama's Habitual Felony Offender Act as constitutional. He argued that it violated both the Eighth Amendment’s prohibition of cruel and unusual punishment and Fourteenth Amendment’s guarantee of equal protection under law. Brennan contended that a mandatory life sentence without parole for a non-violent crime was disproportionate and overly harsh, especially considering defendant had committed only property crimes in his past offenses. Furthermore, he criticized how this sentencing scheme disproportionately affected poor defendants who were unable to afford quality legal representation or post bail before trial - thus increasing their chances of receiving such severe sentences due to prior convictions on record even if they were minor offenses.