In the case of Valentine, Chairman of the Iowa State Board of Assessment and Review, et al. v. Great Atlantic & Pacific Tea Co., 1936, The Great Atlantic & Pacific Tea Company (A&P) challenged an increase in its property tax assessment by the state board in Iowa. A&P argued that their properties were unfairly assessed at a higher percentage of actual value than other properties within the same class across different counties. They claimed this violated both equal protection and due process clauses under Fourteenth Amendment to U.S Constitution. The Supreme Court ruled against A&P stating that while there may be discrepancies between assessments among different counties or classes, it did not necessarily mean they were intentional or systematic discrimination which would violate constitutional rights. The court held that occasional inequalities do not amount to denial of equal protection unless there is clear proof showing deliberate intent for such inequality.

In the dissenting opinion for Valentine, Chairman of the Iowa State Board of Assessment and Review, et al. v. Great Atlantic & Pacific Tea Co., Justice Stone argued that the Court erred in its interpretation of due process rights under the Fourteenth Amendment. He contended that there was no violation as long as a state's tax assessment method is not arbitrary or discriminatory, even if it results in different valuations for similar properties across counties. The justice believed that differences arising from local administration do not necessarily constitute discrimination at a state level and should be addressed by states themselves rather than federal courts intervening on constitutional grounds.