The case of New Orleans Tax Payers' Protective Association v. Sewerage and Water Board of New Orleans in 1914 revolved around a dispute over the constitutionality of certain tax assessments imposed by the city's water board. The plaintiffs, a group representing local taxpayers, argued that these taxes were unconstitutional under both state and federal law because they exceeded the limits set for municipal indebtedness and violated due process rights. However, the Supreme Court ruled against them on both counts. It held that since the water board was an independent entity separate from the city government itself, its debts did not count towards municipal debt limits. Furthermore, it found no violation of due process as there had been sufficient notice given about tax assessments and opportunities to contest them.

The dissenting opinion in the case of New Orleans Tax Payers' Protective Association v. Sewerage and Water Board of New Orleans argued that the majority's decision was a misinterpretation of both state law and constitutional principles. The dissent contended that the creation of a public corporation by the city, which would be exempt from taxation, violated Louisiana's constitution. It also asserted that this arrangement allowed for an unfair distribution of tax burdens among citizens, as it effectively shifted taxes onto private property owners while allowing publicly owned utilities to operate tax-free. Furthermore, they disagreed with the majority’s view on “public purpose,” stating it should not include activities like supplying water or providing sewer services because these are typically handled by private corporations rather than government entities. They believed such interpretation could lead to potential misuse where any activity could be labeled as serving a "public purpose" justifying exemption from taxation.