In the 1924 case of Lee et al. v. Osceola & Little River Road Improvement District No. 1 of Mississippi County, Arkansas, the United States Supreme Court ruled in favor of the defendants (Osceola & Little River Road Improvement District). The plaintiffs (Lee and others) had challenged a tax assessment on their lands by arguing that it was unconstitutional under both state and federal law because they were not given an opportunity to contest it before it was imposed. However, the court found that due process had been followed as there were provisions for challenging such assessments within Arkansas law itself which could have been utilized by them but weren't. Therefore, since these procedures existed at a state level and provided adequate protection for landowners' rights to due process under the Fourteenth Amendment, no violation occurred.

In the dissenting opinion for Lee et al. v. Osceola & Little River Road Improvement District No. 1 of Mississippi County, Arkansas, Justice McReynolds disagreed with the majority's decision to uphold a tax assessment on landowners in a road improvement district without giving them an opportunity to challenge it beforehand. He argued that this violated their due process rights under the Fourteenth Amendment because they were not given notice or an opportunity to be heard before being deprived of their property through taxation. Furthermore, he contended that there was no emergency situation justifying such deprivation without prior hearing and thus found the law authorizing such assessments unconstitutional.