In Baker v. USD 229 Blue Valley, No. 20-3054, 2020 WL 6437964 (10th Cir. 2020), the U.S. Court of Appeals for the Tenth Circuit affirmed the district court's dismissal of Baker's putative class action complaint for lack of standing. Plaintiff Baker sued to invalidate various Kansas statutes that require children to be vaccinated before attending school or other childcare. But those laws allow for religious exemptions, which Baker received and which allowed her son to attend pre-school. In an effort to establish standing, Baker advanced a series of arguments based on possible future harm, but the Tenth Circuit concluded that Baker's theories failed to satisfy Article III's requirements.