## Facts

- Colorado’s State Board of Equalization and Tax Commission ordered a uniform 40% increase in the valuation of all taxable property in the City and County of Denver.
- Bi-Metallic Investment Company owned real estate in Denver and alleged the increase would raise its tax burden.
- Bi-Metallic sought to enjoin the state entities from enforcing the order and to prevent the local assessor from implementing it.
- Bi-Metallic argued the order was adopted without notice or an opportunity to be heard, violating the Fourteenth Amendment’s Due Process Clause.
- The order applied across the board to all Denver property owners and did not involve individualized determinations.

## Issues

1. Whether the Fourteenth Amendment’s Due Process Clause requires notice and an opportunity to be heard for each affected property owner before a state body adopts a generally applicable order increasing property valuations citywide.

## Decision

- The Supreme Court affirmed the dismissal of the suit.
- The Court held that due process did not require individualized notice and hearing before adoption of a general, uniformly applicable valuation increase.
- The Court addressed only the federal due process question and did not reconsider state-law remedial or equitable-policy matters.

## Legal Principles

- The Due Process Clause does not require individualized notice and hearing when government action is rulemaking or quasi-legislative in character and affects a large number of persons equally.
- Procedural due process hearing requirements generally attach to administrative actions that determine rights based on individual grounds and affect a small, identifiable group in a particularized way.
- For broadly applicable governmental decisions, democratic accountability through the political process is the principal safeguard rather than individualized participation in the decision.
- Practical limits on administration permit government to adopt generally applicable measures without providing every affected person a direct opportunity to argue before adoption.

## Conclusion

A uniform, citywide increase in property valuation is a generally applicable governmental measure for which the Fourteenth Amendment does not require individualized notice and an opportunity to be heard; affected taxpayers’ protection lies in political accountability and ordinary mechanisms for contesting individual assessments where applicable.


Bi-Metallic Inv. Co. v. State Bd. of Equalization, 239 U.S. 441 (1915)