Bi-Metallic Investment Co. v. State Board of Equalization
Citation: 239 U.S. 441 (U.S. Supreme Court, 1915)
Facts
The Colorado State Board of Equalization and the Colorado Tax Commission ordered a uniform 40% increase in the valuation of all taxable property in Denver. The increase applied across the board to all Denver property owners without any individual hearing. Bi-Metallic Investment Co. challenged the order as a denial of due process because no opportunity for a hearing had been provided.
Issue
Does the Due Process Clause require individual hearings when the government takes action that affects a large class of persons generally, rather than specific identified individuals?
Holding
The Supreme Court held that no individual hearing was required. When a rule or order applies to a large number of persons equally, those persons have no constitutional right to be heard individually before the rule takes effect. Their recourse is through the political process — by influencing the lawmakers who control the agency.
Rule
When government action is legislative or rulemaking in character — applying generally and prospectively to a large, open-ended class of persons — due process does not require individual notice and hearing. The political process provides sufficient protection for those affected by general rules.
Significance
Bi-Metallic is the companion case to Londoner v. Denver and together they establish the adjudication/rulemaking distinction at the core of administrative procedure. Bi-Metallic explains why rulemaking does not require individualized hearings: when government acts generally, no individual has a special claim to be heard because all are affected alike and political accountability substitutes for judicial-style process. This distinction later shaped the APA’s bifurcated procedural tracks for rulemaking and adjudication.