Bi-Metallic Investment Co. v. State Board of Equalization
, 239 U.S. 441 (1915), was a United States Supreme Court
case which held that due process
protections only attach to administrative activities in which a small number of people are concerned, who are exceptionally affected by the act, in each case upon individual grounds. By contrast, rule-making or quasi-legislative activities that affect a large number of people without regard to the facts of individual cases do not implicate due process protections. It is an important case in American administrative law
Facts and procedural posture
The State Board of Equalization of the state of Colorado
and the Colorado Tax Commission
ordered that the valuation of all taxable property in Denver be increased by forty percent. Plaintiff company brought suit alleging that it had been deprived of its due process protections because a tax had been levied against its property without it being afforded an opportunity to be heard, thereby unconstitutionally depriving it of property. The Colorado Supreme Court
ordered that the suit be dismissed.
The Supreme Court of the United States affirmed the dismissal, ruling that no due process rights are implicated in a tax levied against a large number of people.
Are all property owners entitled to an opportunity to be heard prior to adoption of an administrative order that increases property taxes?
Holding and decision
The Due Process clause of the Fourteenth amendment
provides that the... Read More