In the case of Mitchell, Governor, and Bloxham, Comptroller, of Florida v. Furman in 1900, the U.S Supreme Court dealt with a dispute over land ownership rights in Florida. The plaintiff was an African American man named John Donaldson Furman who claimed that he had been unfairly deprived of his property by state officials due to racial discrimination. He argued that this violated his Fourteenth Amendment rights which guarantee equal protection under law regardless of race or color. However, the court ruled against him stating that there was no evidence to support his claim for racial discrimination as it appeared that all procedures were followed correctly during foreclosure proceedings on his property for unpaid taxes. Furthermore, they stated that even if such allegations were true it would not have affected their decision because states are allowed to enforce tax laws without interference from federal courts unless there is clear violation of constitutional rights.

In the dissenting opinion for Mitchell, Governor, and Bloxham, Comptroller of Florida v. Furman (1900), Justice Harlan argued that the state's action in selling a railroad company's property to pay off its debts was not unconstitutional. He believed that it did not violate due process rights because creditors have a right to be paid from their debtor’s assets. Furthermore, he disagreed with the majority view that this case involved an impairment of contract obligations by arguing that no contractual obligation existed between the state and bondholders which could be impaired by such sale. The justice also contended against any violation of equal protection clause as all similarly situated entities were treated alike under Florida law regarding debt repayment through asset liquidation.