In the case of Hughes Brothers Timber Company v. Minnesota, 1926, the U.S Supreme Court dealt with a dispute over taxation on timberland property in Minnesota. The Hughes Brothers Timber Company argued that they were unfairly taxed by the state of Minnesota due to an alleged discrepancy between their tax assessment and those given to similar properties owned by other companies or individuals within the same county. They claimed this constituted a violation of their Fourteenth Amendment rights which guarantees equal protection under law. However, after reviewing evidence presented from both sides including assessments for various properties across different years, the court ruled against Hughes Brothers Timber Co., stating that there was no clear proof showing intentional discrimination in tax assessment practices by local authorities towards them specifically as compared to others similarly situated within St Louis County where their lands were located.

The dissenting opinion in the case of Hughes Brothers Timber Company v. Minnesota argued that the state's tax on timber was not unconstitutional. The justice disagreed with the majority's view that this tax violated due process rights, arguing instead that it was a legitimate exercise of state power to levy taxes for public purposes. They contended that there was no deprivation of property without due process because the company had ample opportunity to challenge their assessment before paying any money and could have sought relief through legal channels if they believed their assessment was unfair or inaccurate. Furthermore, they asserted that just because a tax may be burdensome does not make it unconstitutional; rather, its legality depends on whether it is applied fairly and uniformly across all similarly situated entities.