The Stewart Dry Goods Co. v. Lewis et al., 1934, is a U.S Supreme Court case that revolved around the constitutionality of a Kentucky tax statute. The law imposed an annual graduated tax on merchants and retailers based on their gross sales receipts, which was challenged by Stewart Dry Goods Company as unconstitutional under the Fourteenth Amendment's Equal Protection Clause. They argued it unfairly discriminated against large businesses in favor of small ones due to its progressive nature (higher rates for higher gross sales). However, the court upheld the validity of this taxation scheme stating that it did not violate equal protection rights because there was no arbitrary or unreasonable discrimination involved in such classification for taxation purposes; rather it served a legitimate state interest - raising revenue without burdening smaller businesses excessively.

In the dissenting opinion for Stewart Dry Goods Co. v. Lewis, Justice McReynolds disagreed with the majority's ruling that upheld a Kentucky tax law imposing higher taxes on chain stores than on independent retailers. He argued that this law violated the Equal Protection Clause of the Fourteenth Amendment because it discriminated against certain businesses without any reasonable basis or justification related to public welfare or policy objectives. According to him, there was no substantial difference between chain and independent stores in terms of their impact on society or economy which could justify such differential treatment under taxation laws; both types of businesses were engaged in similar activities and contributed equally towards state revenues through sales taxes and other levies. Therefore, he believed that this arbitrary discrimination amounted to an unconstitutional denial of equal protection rights guaranteed by the Constitution.