In the case of Davis, Assessor-Collector of Taxes, Bexar County, Texas v. Mabry et al., 1964, the Supreme Court ruled on a dispute regarding property tax assessments in Texas. The plaintiffs were homeowners who claimed that their properties had been assessed at full market value while other properties in the same county were assessed at a fraction of their worth. This discrepancy violated equal protection laws under the Fourteenth Amendment as it resulted in unequal taxation rates for different residents within the same jurisdiction. The court held that if such systematic and intentional discrimination was proven to exist by substantial evidence then it would indeed violate equal protection rights guaranteed by constitution law.

In the dissenting opinion for Davis, Assessor-Collector of Taxes, Bexar County, Texas v. Mabry et al., Justice Harlan disagreed with the majority's decision to strike down a Texas statute that allowed tax assessors to value property at its "fair cash market value." He argued that this standard was not inherently discriminatory or unconstitutional as it did not favor one group over another. Instead, he believed any discrepancies in assessments were due to administrative errors rather than systemic bias within the law itself. Furthermore, he contended that such issues should be addressed by state courts before reaching federal level. Lastly, Justice Harlan expressed concern about potential implications of this ruling on other states' taxation systems and warned against judicial interference in complex matters better suited for legislative resolution.