In the case of Allegheny Pittsburgh Coal Co. v. County Commission of Webster County, West Virginia (1988), the U.S Supreme Court ruled in favor of Allegheny Pittsburgh Coal Company, stating that Webster County's method for assessing property tax violated the Equal Protection Clause under the Fourteenth Amendment. The county had been using a system where recently purchased properties were assessed at their purchase price while similar properties held by long-term owners continued to be assessed based on outdated values, resulting in significant disparities between recent and long-term buyers' taxes. The court found this practice unconstitutional as it created an arbitrary and irrational classification scheme without any legitimate state interest being served.

In the dissenting opinion for Allegheny Pittsburgh Coal Co. v. County Commission of Webster County, West Virginia, Justice Scalia argued that the majority's decision was a departure from established precedent regarding equal protection claims in tax cases. He contended that it is not unusual or unconstitutional for different properties to be assessed at different rates based on when they were last sold or evaluated. Furthermore, he pointed out that there are many legitimate reasons why a state might want to assess property values differently and these should not be second-guessed by the courts unless there is clear evidence of intentional discrimination which he believed was absent in this case.