In the 1921 case of Crane v. Hahlo et al., the U.S. Supreme Court dealt with a dispute over property tax assessments in New York City. The plaintiff, administratrix of Sauer's estate, argued that her property had been unfairly assessed at a higher value than other similar properties in the area, thus violating her constitutional right to equal protection under law as stipulated by the Fourteenth Amendment. She sought relief from these allegedly discriminatory taxes and claimed that she was entitled to repayment for past excessive payments made due to this unfair assessment practice. The court ruled against Crane on both counts: it held that there was no evidence proving intentional discrimination or systematic undervaluation by city officials; furthermore, even if such proof existed, it would not entitle Crane to recover past tax payments because taxpayers are expected to challenge their assessments before paying them rather than seeking refunds afterwards. This decision reinforced two important principles: first, courts will not interfere with local taxation unless clear violations of constitutional rights can be proven; secondly, taxpayers must promptly contest perceived injustices instead of acquiescing and then trying retroactively seek redress.

In the dissenting opinion for Crane v. Hahlo et al., Justice Holmes argued that the majority's decision to uphold a tax assessment on property in New York City was incorrect because it failed to consider whether or not the assessed value of the property accurately reflected its market value. He contended that, according to established legal principles and precedents, tax assessments should be based on fair market values rather than arbitrary figures set by city officials. Furthermore, he criticized the majority for ignoring evidence suggesting that this particular assessment had been inflated due to corruption within local government agencies responsible for setting property taxes. In his view, such behavior constituted an abuse of power and violated taxpayers' rights under both state law and federal constitution.