In the case of Parsons, Town Clerk of the Town of Hubbardton, et al. v. Buckley et al., 1964, residents and taxpayers in Vermont challenged a state law that allowed towns to tax non-resident owners at a higher rate than resident property owners. The plaintiffs argued this was discriminatory and violated their rights under the Equal Protection Clause of the Fourteenth Amendment. However, both lower courts ruled against them stating that there were rational reasons for such differential treatment - namely encouraging home ownership among residents and discouraging speculative land purchases by non-residents which could drive up local real estate prices beyond what locals can afford. The U.S Supreme Court declined to review these decisions thereby effectively affirming them without making any new legal precedent or interpretation itself on this issue.

In the dissenting opinion for Parsons, Town Clerk of the Town of Hubbardton, et al. v. Buckley et al., Justice Harlan argued that the Court should not have intervened in this case as it was a matter best left to state courts and legislatures. He believed that there were no substantial federal questions involved and thus saw no reason for Supreme Court intervention. The justice also expressed concern about potential overreach by federal courts into matters traditionally handled at the state level, cautioning against unnecessary interference with local affairs unless absolutely necessary to uphold constitutional rights or principles.