In the 1893 case of Meddaugh v. Wilson, the United States Supreme Court was asked to determine whether a New York law that allowed for the seizure and sale of property without notice or hearing violated due process rights under the Fourteenth Amendment. The plaintiff, Meddaugh, had his property seized by Wilson who acted on behalf of creditors in accordance with this state law. The court ruled unanimously in favor of Wilson, upholding the constitutionality of such laws. They reasoned that since these laws were not new but rather longstanding common-law practices dating back centuries in England and America alike; they did not violate due process rights as understood at time when Fourteenth Amendment was adopted.

In the dissenting opinion for Meddaugh v. Wilson, it was argued that the majority's decision to uphold a tax assessment on property owned by non-residents of a state violated principles of equal protection under the law. The dissenting justices believed that there should be no distinction in taxation between residents and non-residents; both groups should be treated equally under tax laws. They contended that if states were allowed to impose higher taxes on out-of-state landowners, this could lead to unfair treatment and discrimination against those who do not reside within their borders but still own property there. This would undermine one of the key tenets of our legal system - equality before the law - which they felt was being disregarded by allowing such differential taxation practices.