In the 1906 case of Quinlan v. Green County, Kentucky, the U.S Supreme Court was tasked with deciding on a dispute over land ownership. The plaintiff, Quinlan, claimed that he had purchased a tract of land from an individual who had obtained it through inheritance. However, Green County argued that they were the rightful owners as they had bought the same piece of property at a delinquency tax sale years prior to Quinlan's purchase and therefore held legal title to it. The court ruled in favor of Green County based on its interpretation of Kentucky state law which stated that if taxes are not paid for five consecutive years by any owner or claimant then their rights are forfeited and transferred to whoever purchases them at a public auction organized by county officials. In this case, since neither the original inheritor nor Quinlan paid these taxes during said period before his purchase while Green County did after theirs; thus making them lawful proprietors according to local legislation.

The dissenting opinion in the Quinlan v. Green County, Kentucky case argued that the majority's decision to uphold a tax assessment on Quinlan's property was incorrect and unfair. The dissenting justices believed that the county had violated Quinlan's constitutional rights by assessing his property at a higher value than other similar properties in the area, thereby imposing an unequal and excessive tax burden on him. They contended that this practice was discriminatory and arbitrary, violating both state law and principles of equal protection under the Fourteenth Amendment of U.S Constitution. Furthermore, they disagreed with majority’s interpretation of “uniformity” clause within state constitution as it allowed for such disparities in taxation practices to occur without any legal recourse for affected individuals like Mr.Quinlan.