In the case of Rohr Aircraft Corp. v. County of San Diego et al., 1959, the U.S Supreme Court ruled in favor of Rohr Aircraft Corporation, a manufacturer and supplier for military aircrafts. The company had challenged its property tax assessment by San Diego County on grounds that it was discriminatory and violated their equal protection rights under the Fourteenth Amendment because other businesses were not similarly taxed for their inventory held for immediate use in manufacturing products to fulfill government contracts. The court agreed with Rohr's argument stating that such taxation was indeed unconstitutional as it resulted in unequal treatment between different types of businesses without any rational basis or justification from the county’s side.

In the dissenting opinion for Rohr Aircraft Corp. v. County of San Diego, it was argued that the majority's decision to uphold a tax assessment on federal government property leased by a private corporation contradicted previous rulings and principles established by the Court. The dissent emphasized that this ruling effectively allowed local governments to indirectly tax federal property, which is constitutionally immune from taxation under Supremacy Clause of U.S Constitution. It was also pointed out that such an interpretation could lead to potential abuses where states might impose excessive taxes on lessees in order to indirectly extract revenue from the Federal Government itself or discourage companies from leasing federal properties due to high tax burdens.