In the case of Wade v. Travis County in 1898, the U.S Supreme Court dealt with a dispute over land ownership and tax payments. The plaintiff, Wade, claimed that he had been wrongfully taxed by Travis County for property he did not own during the years 1885 to 1891. He argued that this was due to an error in recording his name instead of another individual's who held similar properties within the county. However, it was found that there were no records indicating such an error or any proof showing payment of taxes on behalf of someone else by him during those years. The court ruled against Wade stating that even if there had been a mistake made by officials while recording names for taxation purposes; it would not be sufficient grounds to recover money paid as taxes unless evidence could prove beyond doubt about such errors leading to wrongful taxation. Furthermore, they stated that mere allegations without substantial proofs are insufficient when challenging state laws related to taxation which have already been executed and enforced duly under legal procedures established therein.

The dissenting opinion in the case of Wade v. Travis County argued that the majority's decision was inconsistent with previous rulings on similar matters, particularly those involving tax assessments and their relationship to due process rights under the Fourteenth Amendment. The dissent contended that a state has no right to levy taxes without providing taxpayers an opportunity for hearing or review, which they believed had been denied in this case. They also disagreed with the majority's interpretation of what constitutes "property" under Texas law, arguing it should include all assets rather than just real estate and tangible personal property as determined by the court. Furthermore, they expressed concern about potential abuses of power if states were allowed unchecked discretion over taxation procedures without federal oversight or intervention when necessary to protect individual rights.