In the 1920 case of People of the State of New York on the Relation of The Troy Union Railroad Company v. Mealy et al., as Assessors, et al., the U.S Supreme Court dealt with a dispute over property tax assessment. The Troy Union Railroad Company argued that its property was unfairly and excessively assessed by local tax assessors in violation of both state law and their Fourteenth Amendment rights to equal protection under law. They contended that other similar properties were not assessed at such high rates, making their taxation discriminatory and unjust. However, the court ruled against them stating that there was no evidence showing intentional discrimination or inequality in treatment by tax authorities. It held that mere differences in assessments did not constitute a violation unless it could be proven they resulted from an intention to discriminate or were so grossly unequal as to amount to constructive fraud.

The dissenting opinion in the case of People of the State of New York on The Relation Of The Troy Union Railroad Company v. Mealy et al., as Assessors, et al., argued that the majority's decision was inconsistent with previous rulings and principles established by the court. They contended that a railroad company should not be assessed for taxation based on property it does not own or control but merely has permission to use. This assessment would result in double taxation since both entities -the owner and user- are taxed for their respective interests in the same property. Furthermore, they disagreed with how intangible assets were valued during tax assessments, arguing this method was arbitrary and unfair because it did not accurately reflect actual value or potential income from these assets.