In the case of Hunter v. City of Pittsburgh in 1907, the U.S Supreme Court ruled that states have broad discretion under the Constitution to draw and redraw municipal boundaries. The court held that citizens do not have a constitutional right to vote on these changes. The dispute arose when Pennsylvania's legislature approved Pittsburgh's annexation of Allegheny City without allowing Allegheny residents to vote on it. Residents argued this violated their Fourteenth Amendment rights by depriving them equal protection under law since they were denied a say in their governance while other cities' residents could vote on similar issues. However, Justice Oliver Wendell Holmes Jr., writing for the majority, stated that there was no inherent right for local self-government within each state guaranteed by constitution; thus, states can alter or abolish municipalities as long as it doesn't infringe upon specific protections provided by federal constitution.

In the dissenting opinion for Hunter v. City of Pittsburgh, Justice Harlan argued that the consolidation of Allegheny into Pittsburgh was unconstitutional because it violated citizens' rights to equal protection under the law. He contended that this merger effectively stripped Allegheny residents of their political identity without their consent or a vote on the matter, which he viewed as an infringement upon democratic principles and individual liberties. Furthermore, he expressed concern over potential abuses of power by state legislatures if they were allowed to alter or dissolve municipal corporations at will without considering the wishes or best interests of affected citizens. In his view, such actions could lead to arbitrary and unjust government interference in local affairs.