In the 1904 case Wheeler v. Plumas County, a dispute arose over taxes levied on timberland in California. The plaintiff, Wheeler, argued that he was unfairly taxed because his land was assessed at a higher value than other similar properties in the county. He claimed this violated his rights under the Equal Protection Clause of the Fourteenth Amendment to the U.S Constitution which requires equal treatment under law for all citizens. However, upon review by lower courts and eventually reaching Supreme Court level it was found that there were no constitutional violations involved with how Plumas County had conducted its tax assessments on Wheeler's property or any others within their jurisdiction. The court ruled against Mr.Wheeler stating that while there may have been discrepancies between different parcels of land being valued differently for taxation purposes these differences did not amount to an unconstitutional violation as they fell within acceptable limits set out by state laws governing such matters.

The dissenting opinion in Wheeler v. Plumas County argued that the majority's decision to allow a county to tax property owned by non-residents differently than property owned by residents was unconstitutional. The dissent contended that this ruling violated the Equal Protection Clause of the Fourteenth Amendment, which guarantees all citizens equal protection under the law. They believed that differential taxation based on residency status created an unfair burden for non-resident property owners and amounted to discrimination against them. Furthermore, they asserted that such a policy could discourage investment and economic development within counties implementing it as it may deter out-of-county individuals from purchasing or maintaining properties there due to higher taxes.