In the case of Nelson et al. v. County of Los Angeles et al., 1959, the U.S Supreme Court dealt with a dispute over property tax assessments in California. The plaintiffs, Mr and Mrs Nelson, argued that their properties were assessed at full cash value while other properties in the same county were assessed at lesser values which they claimed was discriminatory and violated equal protection under law as guaranteed by the Fourteenth Amendment to US Constitution. The court ruled against them stating that there is no federal constitutional requirement for uniformity in state or local taxation; it's not necessary for all property to be taxed equally or uniformly within a jurisdiction as long as there is no intentional systematic discrimination present.

In the dissenting opinion for Nelson et al. v. County of Los Angeles et al., Justice Frankfurter, joined by Justices Harlan and Whittaker, argued that the majority's decision to reverse the California Supreme Court was an overreach of federal authority into state matters. He contended that it is not within their jurisdiction to review a State's interpretation of its own laws unless there is a clear violation or misinterpretation of Federal law or Constitution involved. The dissenters believed this case did not meet those criteria as it primarily concerned local tax assessments - a matter traditionally left to states' discretion under principles of federalism. They also disagreed with the majority’s view on due process grounds, arguing that taxpayers had sufficient notice and opportunity for hearing before taxes were assessed and collected in this case.