In the 1891 case of Ficklen v. Shelby County Taxing District, the U.S. Supreme Court dealt with a dispute over taxation and property rights. The plaintiff, Ficklen, was a resident of Memphis who owned bonds issued by the city before it became part of Shelby County's taxing district in Tennessee. When the county attempted to tax these bonds as personal property, Ficklen objected on grounds that this violated his contract rights under Article I Section 10 Clause 1 (the Contract Clause) of the Constitution which prohibits states from passing laws impairing contractual obligations. The court ruled against him stating that while cities have certain powers to make contracts for public purposes such as issuing bonds; they do not possess inherent sovereignty like states or nations and their power is subject to control by state legislature unless expressly forbidden by constitutional provisions. Therefore, when Memphis ceased being an independent municipality and merged into Shelby County’s taxing district due to legislative action; its bondholders were subjected to new taxation rules without any violation of constitutionally protected contract rights.

The dissenting opinion in the case of Ficklen v. Shelby County Taxing District argued that the tax imposed by the district was unconstitutional because it violated both state and federal laws. The justice believed that this taxation was a form of double taxation, as property owners were being taxed twice for their land - once by the county and again by the taxing district. This, according to him, amounted to an unlawful taking without due process of law under both Tennessee's constitution and U.S Constitution’s Fourteenth Amendment. He also pointed out inconsistencies in how properties within different districts were assessed for taxes which he viewed as unequal treatment violating equal protection clause under Fourteenth Amendment.