In State ex rel. Atlantic Coast Line Railway Co. v. State Board of Equalizers, 84 Fla. 592, 94 So. 681 (Fla. 1922), a taxpayer challenged the Comptroller's assessment and valuation of its railroad property and appealed to the State Board of Equalizers. The board refused to accept the appeal. After the taxpayer filed a writ of mandamus, the board argued as a defense that the statute that gave it appellate jurisdiction was unconstitutional. The Court held that the Board's defensive challenge to the statute violated the separation of powers doctrine because it impermissibly asserted "the right of a branch of government other than the judiciary, to declare an act of the Legislature to be unconstitutional." Id. at 682. The Court noted that "the doctrine that the oath of office of a public official requires him to decide for himself whether or not an act is constitutional before obeying it will lead to strange results, and set at naught other binding provisions of the Constitution." Id. at 683. In State ex rel. Atlantic Coast Line Railway Co. v. State Board of Equalizers, a railway company was dissatisfied with the Comptroller's assessment of its property and filed an appeal with the State Board of Equalizers pursuant to chapter 8584, section 7, Laws of Fla. (1921). When the board refused to hear the appeal, the railway petitioned for a writ of mandamus compelling the board to hear its appeal, and the board responded by arguing that sections 6 and 7 of the law were unconstitutional. The Court framed the issue presented as whether a ministerial officer has "the right or power to declare an act unconstitutional, or to raise the question of its unconstitutionality without showing that he will be injured in person, property, or rights by its enforcement." Atlantic Coast Line, 94 So. at 682. In answering in the negative, the Court explained that "every act of the Legislature is presumptively constitutional until judicially declared otherwise, and the oath of office 'to obey the Constitution' means to obey the Constitution, not as the officer decides, but as judicially determined." Id. at 683. The Court found that to allow a public official to refuse to obey a law would be "the doctrine of nullification, pure and simple." Id. As a result, the Court held that an allegation of unconstitutionality is "unwarranted, unauthorized, and affords no defense" in a mandamus proceeding. Id. at 685. The Atlantic Coast Line decision promotes an important public policy of ensuring the orderly and uniform application of state law and is consistent with over eighty years of legislative enactments relating to tax assessment litigation.