The U.S. Supreme Court case Deposit Bank of Owensboro v. Owensboro in 1898 revolved around a dispute between the city of Owensboro, Kentucky and the Deposit Bank of Owensboro regarding taxation. The bank claimed that its property was being taxed at an unfair rate compared to other properties within the city limits, violating their Fourteenth Amendment rights to equal protection under law. The court ruled in favor of the City of Owensboro, stating that it is not unconstitutional for different types or classes of property to be taxed at varying rates as long as there is no discrimination against out-of-state entities or arbitrary classification without reasonable basis.

The dissenting opinion in the case of Deposit Bank of Owensboro v. Owensboro argued that the tax imposed by the city was not a violation of any contract between Kentucky and the bank, nor did it infrive upon any constitutional rights. The justice believed that there was no obligation on part of Kentucky to exempt banks from taxation, as such an exemption would be contrary to public policy and detrimental to state revenue. Furthermore, he asserted that even if such a contractual obligation existed, it could not supersede or limit legislative power over matters concerning taxation which is essential for government functioning. He also emphasized that states should have full authority over their internal affairs without federal interference unless absolutely necessary.