In the case of Stanislaus County v. San Joaquin and King's River Canal and Irrigation Company, 1903, the U.S Supreme Court was tasked with determining whether a California state law that exempted certain properties from taxation was constitutional under the Fourteenth Amendment. The property in question belonged to San Joaquin and King's River Canal and Irrigation Company (SJKRCIC), which had been granted tax-exempt status by California for its canals, ditches, flumes etc., used for irrigation purposes. Stanislaus County argued that this exemption violated equal protection laws as it unfairly shifted tax burdens onto other property owners within the county. However, SJKRCIC contended that their operations provided public benefits such as flood control and agricultural enhancement thus justifying their exemption. The court ruled in favor of SJKRCIC stating that states have broad discretion when classifying different types of property for taxation purposes so long they do not violate any specific federal restrictions or fundamental principles of justice; hence there is no violation of equal protection clause here since these exemptions were made on reasonable grounds i.e., promoting agriculture through irrigation facilities.

In the dissenting opinion for Stanislaus County v. San Joaquin and King's River Canal and Irrigation Company, Justice Harlan argued that the majority misinterpreted California law regarding water rights. He contended that under state law, counties have a right to all unappropriated waters within their boundaries for public use. The majority decision allowed private companies to divert water from its natural course without any compensation or consideration of public interest, which he believed was contrary to both common law principles and California statutes. Furthermore, he disagreed with the majority's view that irrigation canals are not considered 'public uses' under eminent domain laws because they serve agricultural interests rather than urban populations. To him, this distinction was arbitrary as it ignored how vital irrigation is in arid regions like California where agriculture plays a significant role in local economies.