The case of Hopkins v. Clemson Agricultural College of South Carolina in 1910 revolved around the issue of taxation and public institutions. The plaintiff, Hopkins, was a taxpayer who sued Clemson Agricultural College (now known as Clemson University), arguing that it was unlawfully exempted from paying taxes despite being a profitable entity engaged in commercial activities such as manufacturing fertilizer for sale. He contended that this exemption violated the Fourteenth Amendment's Equal Protection Clause because other similar entities were required to pay taxes. However, the Supreme Court ruled against him stating that since the college was established by statute for educational purposes and its profits were used solely for maintaining and operating itself without any private interests involved, it could be considered an arm or agency of the state government which is generally immune from taxation under U.S law.

In the dissenting opinion for Hopkins v. Clemson Agricultural College of South Carolina, Justice Harlan argued that the majority's decision was a misinterpretation of the Fourteenth Amendment and its equal protection clause. He contended that denying Thomas E. Miller, an African American man, admission to Clemson Agricultural College solely based on his race was unconstitutional discrimination. Justice Harlan believed this case represented a clear violation of civil rights protected by federal law and should not be left to state jurisdiction or private entities like educational institutions as determined by the majority ruling. The justice emphasized that racial segregation in public education is fundamentally unequal treatment under U.S law and contradicts principles of fairness and equality upon which America prides itself.