The Henrietta Mills v. Rutherford County, North Carolina case in 1929 revolved around a tax dispute. The Henrietta Mills, a textile company based in North Carolina, argued that the county's method of assessing property taxes was unfair and unconstitutional because it did not assess all properties at their true value as required by state law. Instead, the mill claimed that the county assessed its property at full value while undervaluing other properties to keep their taxes lower. This resulted in an unequal distribution of tax burden which violated both state and federal constitutions' equal protection clauses. However, the Supreme Court ruled against Henrietta Mills stating that even if there were irregularities or inequalities in assessment practices across different types of property within a jurisdiction; this would not necessarily constitute discrimination under constitutional law unless these disparities are intentional or systematic. Furthermore, they stated it is primarily up to states to determine how they levy and collect taxes as long as those methods do not violate any specific provisions outlined within either constitution.

In the dissenting opinion for The Henrietta Mills v. Rutherford County, North Carolina case in 1929, it was argued that the majority's decision to allow a county to tax property outside its jurisdiction contradicted previous rulings and principles of fairness. The dissenting justices believed that allowing such taxation would lead to double taxation as properties could be taxed by both their actual location and any other area where they might have some connection or use. They also pointed out that this ruling could potentially open up all personal property anywhere in the country to being taxed by every locality with which it has any sort of relationship, leading to an absurd result. Furthermore, they noted that there were no clear guidelines on how far these taxing powers extended or what constituted sufficient contact for a locality to impose taxes on a piece of property.