In the 1906 case of Rearick v. Pennsylvania, the U.S. Supreme Court dealt with a dispute over tax assessment and collection procedures in Pennsylvania. The plaintiff, J.B. Rearick, argued that his property was unfairly assessed for taxation purposes at an inflated value compared to other properties in his county, violating his rights under the Equal Protection Clause of the Fourteenth Amendment. He also claimed that he had no effective legal remedy available within state law to challenge this unfair treatment. The Supreme Court ruled against Rearick's claims on both counts. First, it held that discrepancies or errors in tax assessments did not necessarily constitute violations of equal protection unless they were deliberate and systematic - which was not proven by Rearick's evidence about one year’s assessment practices alone. Secondly, regarding lack of remedies under state law: while acknowledging some deficiencies in Pennsylvania's system for challenging tax assessments (such as limited timeframes), it found these issues insufficient to justify federal intervention into what is generally considered a matter reserved for states' jurisdiction – namely local taxation matters.

The dissenting opinion in the Rearick v. Pennsylvania case argued that the state of Pennsylvania did not have the right to seize and sell Mr. Rearick's property without providing him with due process of law, as guaranteed by the Fourteenth Amendment. The justice believed that this action was a clear violation of his constitutional rights, regardless of whether or not he owed taxes on said property. Furthermore, they disagreed with the majority's interpretation that tax collection is an exception to due process requirements; instead arguing that all citizens are entitled to their day in court before being deprived of their property for any reason - including unpaid taxes.