In the 1932 case of Harrisonville v. W.S. Dickey Clay Manufacturing Co., the U.S Supreme Court ruled in favor of W.S. Dickey Clay Manufacturing Co, a private company that had been contracted by the city of Harrisonville to pave its streets with brick and then assess property owners for their share of the cost. The court held that this arrangement violated due process rights under the Fourteenth Amendment because it allowed a private entity to determine tax assessments without any governmental oversight or control, which could lead to arbitrary and unfair results for property owners who were required to pay these costs but had no say in how they were determined.

In the dissenting opinion for Harrisonville v. W.S. Dickey Clay Manufacturing Co., Justice Stone argued that the city of Harrisonville was within its rights to refuse payment on bonds issued for a public improvement project, as it had not received any benefit from the project due to faulty construction by W.S. Dickey Clay Manufacturing Co.. He contended that there was no legal obligation for the city to pay because they did not receive what they were promised in return - a functional sewer system. The majority's decision, he believed, unjustly burdened taxpayers with debt incurred through no fault of their own and without receiving any corresponding benefit.