Bi-Metallic Investment Co. v. State Board of Equalization — Quick Summary

Bi-Metallic Investment Co. v. State Board of Equalization

239 U.S. 441 (1915) (U.S. Supreme Court)

In Brief

Bi-Metallic Investment Co. v.

Key Issue

Does the Due Process Clause require the government to provide individual notice and a hearing before adopting a generally applicable rule—here, a blanket increase in all Denver property valuations—that affects a large number of people in the same way?

The Rule

When a governmental decision is legislative in character—i.e., it is a generally applicable rule or policy affecting a broad class of persons—due process does not require individual notice and an opportunity to be heard. Due process hearing rights attach primarily to adjudicative or quasi-judicial determinations that single out a relatively small number of persons based on individualized facts. The remedy for dissatisfaction with broadly applicable policy choices lies in the political process.

Bottom Line

No. The Supreme Court affirmed, holding that a general, citywide increase in property valuations is a rule of general applicability for which the Constitution does not require individual notice or hearings.

Why It Matters

Bi-Metallic is a touchstone for the adjudication–rulemaking line in administrative law and procedural due process. It is routinely taught alongside Londoner v. Denver to illustrate that individualized assessments often require hearings, while broad policy decisions do not. The case undergirds modern doctrines permitting agencies to adopt rules of general applicability (e.g., tax equalization, rate schedules, environmental standards) without providing individual trial-type hearings, even though many people are significantly affected. Statute-based procedures—such as the Administrative Procedure Act's notice-and-comment rulemaking—may apply, but as a constitutional baseline, due process does not demand individualized hearings for general rules.

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