In the case of City of Phoenix et al. v. Kolodziejski, 1969, the U.S Supreme Court ruled that a city's practice of allowing only property owners to vote in bond elections was unconstitutional as it violated the Equal Protection Clause of the Fourteenth Amendment. The court held that all residents who were qualified voters had an interest in such decisions and should be allowed to participate irrespective of whether they owned real estate or not. This decision expanded on previous rulings which had struck down similar restrictions for school bond issues and other special tax assessments.

In the dissenting opinion for City of Phoenix et al. v. Kolodziejski, Justice Harlan argued that the majority's decision to require voter approval from non-property owners on general obligation bond issues was a misinterpretation of the Equal Protection Clause. He contended that there is a rational basis for limiting voting on such matters to property owners since they are directly affected by changes in property taxes used to repay these bonds. The justice believed this case did not present any compelling reason to overturn longstanding practices and legal precedents allowing states and municipalities discretion in determining who should vote on financial obligations primarily affecting property interests.