In the case of Sunday Lake Iron Company v. Township of Wakefield in 1917, the Supreme Court ruled on a dispute regarding property tax assessment. The Sunday Lake Iron Company argued that their property was overvalued by the township's assessor, leading to an unfairly high tax burden. They claimed this violated their Fourteenth Amendment rights to due process and equal protection under law because they were not given an opportunity to contest the valuation before it was finalized. However, the Supreme Court disagreed with this argument and upheld Michigan state law which allowed for such assessments without prior notice or hearing. The court held that as long as there is a legal avenue available for challenging these assessments after they are made (which existed in Michigan), then due process requirements are satisfied.

In the dissenting opinion for Sunday Lake Iron Company v. Township of Wakefield, Justice Holmes disagreed with the majority's ruling that a state law allowing tax assessments to be challenged only by paying under protest was unconstitutional. He argued that this requirement did not violate due process rights because it merely regulated how and when taxpayers could challenge their assessments, rather than denying them any opportunity to do so. Furthermore, he contended that such laws were necessary for maintaining public revenue streams and preventing frivolous lawsuits from disrupting local governments' financial stability. In his view, requiring payment under protest as a prerequisite for challenging an assessment was no different from other common legal procedures which require some form of compliance before granting access to judicial review.