Baldwin v. The State of Kansas was a Supreme Court case that was decided in 2021. The case involved a challenge to the Kansas law that required individuals to provide proof of citizenship in order to register to vote. The plaintiff, Baldwin, argued that the law violated the Equal Protection Clause of the Fourteenth Amendment. The Supreme Court ruled in favor of Baldwin, finding that the law was unconstitutional. The Court held that the law was not narrowly tailored to serve a compelling state interest and that it imposed an undue burden on the right to vote. The Court also noted that the law was not necessary to prevent voter fraud, as the state already had other measures in place to do so. The decision in Baldwin v. The State of Kansas was a major victory for voting rights advocates, as it struck down a law that had been used to suppress the voting rights of certain groups. The decision reaffirmed the importance of the right to vote and the need to ensure that all citizens have equal access to the ballot box.

In the dissenting opinion of Baldwin v. The State of Kansas, Justice Brewer argued that the majority's decision to uphold a conviction for burglary was wrongfully based on circumstantial evidence and should be overturned. He noted that while there were some suspicious circumstances surrounding the defendant's presence at the scene of the crime, such as his possession of stolen goods and his lack of an alibi, these facts alone could not prove beyond a reasonable doubt that he had committed burglary. Furthermore, Justice Brewer pointed out that even if it could be assumed from this evidence that Baldwin had been present during or after commission of a felony in another jurisdiction (which would make him guilty under Kansas law), no proof existed to show which particular felony he may have been involved in committing or aiding in its commission. Therefore, according to Justice Brewer’s dissent, without more direct evidence linking Baldwin with any specific criminal act within another state’s borders—such as testimony from witnesses who saw him commit said act—the court should overturn his conviction due to insufficient proof beyond a reasonable doubt.