In the case of Hooper et al. v. Bernalillo County Assessor, 1984, the U.S Supreme Court ruled that a New Mexico statute granting property tax exemptions to Vietnam War veterans who resided in the state before May 8, 1976 was unconstitutional as it violated equal protection principles under the Fourteenth Amendment. The court held that there was no rational basis for distinguishing between pre- and post-May 8th residents because both groups were similarly situated with respect to their military service during Vietnam War and subsequent residency in New Mexico. Therefore, treating them differently based on an arbitrary cut-off date did not serve any legitimate state interest and amounted to discrimination against newer residents.

In the dissenting opinion for Hooper et al. v. Bernalillo County Assessor, Justice White argued that the majority's decision was a misinterpretation of the Privileges and Immunities Clause of Article IV and Equal Protection Clause of Fourteenth Amendment. He contended that New Mexico’s tax exemption law did not discriminate against new residents but rather provided benefits to veterans who were residents when it was enacted as a form of compensation for their past services during Vietnam War era. The state had legitimate reasons to limit its generosity only to those who were citizens at that time due to budgetary constraints, he added. Furthermore, he pointed out there is no constitutional requirement for states to extend such benefits indefinitely or make them available universally once they are offered.