In the case of Kelley et al. v. Everglades Drainage District, 1942, the U.S Supreme Court ruled in favor of the Everglades Drainage District against a group of bondholders led by Mr. Kelley who had sued for payment on bonds issued by the district to finance drainage and reclamation projects in Florida's Everglades region. The court held that although there was an implied contract between bondholders and issuers, it did not extend to guaranteeing specific tax rates or revenues for repayment as argued by Mr.Kelley and his co-plaintiffs. Instead, they found that such guarantees would infringe upon state sovereignty rights over taxation policy which are protected under federal law from interference through contracts clause claims unless explicitly stated otherwise within legislation authorizing their issuance.

In the dissenting opinion for Kelley et al. v. Everglades Drainage District, Justice Black argued that the majority's decision was a departure from established constitutional principles regarding taxation and property rights. He contended that Florida’s law allowing special tax districts to levy assessments on land without providing notice or opportunity for hearing violated due process rights under the Fourteenth Amendment of the Constitution. According to him, this lack of procedural safeguards could lead to arbitrary and unfair taxation practices by local authorities which would infringe upon individual property rights protected by constitutionally guaranteed due process protections. Furthermore, he disagreed with the majority's assertion that these taxes were not personal liabilities but rather liens against properties; thus implying owners had no right to contest them before they were imposed.