In the 1934 case of Roberts, Receiver, et al. v. New York City et al., the U.S Supreme Court ruled on a dispute concerning tax assessments in New York City. The plaintiffs argued that their properties were assessed at full value while other properties in the city were not, violating equal protection under law as guaranteed by the Fourteenth Amendment to the Constitution. They sought an injunction against collection of taxes based on these allegedly discriminatory assessments and refunds for previous payments made under such circumstances. The court held that if it was proven there was intentional systematic discrimination in property assessment leading to unequal taxation, then this would constitute a violation of constitutional rights warranting judicial intervention. However, they also stated that occasional unintentional undervaluation or errors did not amount to unconstitutional action. The court further clarified that taxpayers must first seek remedy through state channels before resorting to federal courts unless it is evident those avenues are inadequate or futile. This decision established important precedents regarding taxpayer rights and remedies available when challenging alleged discriminatory practices by local taxing authorities.

In the dissenting opinion for Roberts, Receiver, et al. v. New York City et al., Justice McReynolds expressed his disagreement with the majority's decision to uphold a law that allowed New York City to tax stock transfers occurring within its jurisdiction. He argued that this was an unconstitutional interference with interstate commerce and violated the Due Process Clause of the Fourteenth Amendment because it imposed taxes on transactions taking place outside of New York State. Furthermore, he contended that such taxation could lead to multiple states taxing the same transaction which would be burdensome and unfair for businesses involved in interstate trade. The justice also criticized how broadly defined "within" was in relation to where these transactions took place as it included any transfer recorded or registered within city limits regardless if they were physically conducted elsewhere.