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Amy and Another v. Shelby County Taxing District and Others is a United States Supreme Court case that was decided in 1885. The case involved a dispute between the Shelby County Taxing District and two individuals, Amy and another, over the taxation of certain property. The Shelby County Taxing District had assessed a tax on the property, which the two individuals argued was unconstitutional. The Supreme Court ultimately held that the tax was unconstitutional, as it violated the Fourteenth Amendment's Equal Protection Clause. The Court reasoned that the tax was not based on any rational basis, and thus violated the Equal Protection Clause. The Court also held that the tax was not a valid exercise of the taxing power of the state, as it was not based on any reasonable classification. The Court concluded that the tax was invalid and that the two individuals were not liable for the tax. This case established the principle that taxes must be based on a rational basis in order to be valid.
Justice Harlan delivered the dissenting opinion in Amy & Another v. Shelby County Taxing District & Others, arguing that the majority had erred in its interpretation of state law and federal constitutional provisions. He argued that the Court should have considered whether or not a tax imposed by a taxing district was valid under Tennessee's Constitution before determining if it violated any provision of the United States Constitution. In his view, since there was no evidence presented to show that such taxes were unconstitutional under Tennessee law, then they could not be held invalid on federal grounds either. Furthermore, he believed that even if such taxes did violate some part of Tennessee's constitution, this would still not necessarily mean they were unconstitutional at a federal level as well - only an explicit violation of some clause within the US Constitution itself could render them so. Ultimately Justice Harlan concluded by asserting that it was up to each individual state to decide how best to regulate taxation within their own borders and thus felt strongly against any interference from outside sources like Congress or Federal Courts when doing so.