In the 1942 case of Hughes v. Wendel, County Treasurer et al., the United States Supreme Court ruled in favor of plaintiff Hughes who was contesting a tax assessment on his property. The court found that the county had violated due process by not providing adequate notice to Hughes about changes in his property's assessed value and subsequent increase in taxes owed. This lack of notification denied him an opportunity to challenge these changes before they were implemented, thus violating his rights under the Fourteenth Amendment. The decision underscored that taxpayers must be given sufficient notice and an opportunity to protest any increases or alterations made to their tax assessments.

In the dissenting opinion for Hughes v. Wendel, it was argued that the majority's decision to uphold a tax sale of property without prior personal notice to the owner violated due process rights under the Fourteenth Amendment. The dissenting justices believed that such an action constituted a deprivation of property without adequate notification and opportunity for hearing, which is fundamentally unfair and unconstitutional. They contended that even though state law did not require personal notice before selling tax-delinquent properties, constitutional principles should supersede this provision to ensure fair treatment of citizens' property rights. This view held that while states have broad powers in taxing and collecting taxes, these powers must be exercised within constitutional limits respecting individual rights.