In the 1917 case, Contributors to the Pennsylvania Hospital v. City of Philadelphia et al., the U.S. Supreme Court ruled in favor of The Pennsylvania Hospital against claims made by the City of Philadelphia and others regarding property tax exemption. The hospital was founded in 1751 through private contributions with a charter that exempted its properties from taxation as long as they were used for charitable purposes. However, when it rented out some parts of its land for commercial use while using rental income to fund patient care, local authorities claimed this violated their tax-exempt status and demanded taxes on those portions of land being commercially leased out. The court held that despite these leases, since all profits were directed towards maintaining free beds and other charitable services provided by the hospital, it remained within its original purpose - charity work - thus preserving its right to tax exemption under state law. This decision reinforced legal protections for non-profit organizations utilizing innovative methods to generate funds supporting their mission.

In the dissenting opinion for CONTRIBUTORS TO THE PENNSYLVANIA HOSPITAL v. CITY OF PHILADELPHIA et al., 1917, it was argued that the majority's decision to uphold a city ordinance requiring private hospitals to pay for street improvements contradicted previous rulings and principles of fairness. The dissent pointed out that Pennsylvania Hospital, as a charitable institution providing public benefits, should be exempt from such assessments under established legal precedents recognizing their unique status. Furthermore, they contended that forcing non-profit organizations like this hospital to bear these costs could jeopardize their ability to serve the community effectively. They also questioned whether there was any real benefit derived by the hospital from these improvements or if it was merely an attempt by the city government to shift financial burdens onto other entities without proper justification or equitable considerations.