In the 1896 case of Nelson v. Flint, the United States Supreme Court dealt with a dispute over land ownership in Michigan. The plaintiff, Nelson, claimed that he had purchased a piece of property from an individual who had obtained it through tax sale after its previous owner defaulted on their taxes. However, the defendant, Flint (the city), argued that they were still owed unpaid taxes for this property and therefore held rightful claim to it. The court ruled in favor of Nelson stating that once a deed has been issued following a tax sale - even if there are errors or irregularities involved - any claims against the title must be made within three years as per Michigan law at that time. Therefore since Flint did not make such claims within this period; they lost their right to do so later on.

In the dissenting opinion for Nelson v. Flint, it was argued that the majority's decision to uphold a tax assessment on property owned by non-residents of Michigan violated principles of equal protection under the law as outlined in the Fourteenth Amendment. The dissenting justices believed that this ruling unfairly discriminated against out-of-state landowners and placed an unjust burden upon them simply because they did not reside within Michigan's borders. They also expressed concern over potential abuses of power by local governments who could exploit such discriminatory taxation practices to their advantage at the expense of non-resident property owners. Furthermore, they disagreed with how broadly and arbitrarily "residence" had been defined in determining tax liabilities, arguing that it should be more narrowly construed based on where one actually lives and maintains a permanent home rather than merely owning property there.