Bi-Metallic Investment Co. v. State Board of Equalization
Headline: Court upholds state boards’ 40% revaluation of Denver property, ruling owners need not receive individual hearings before broad countywide tax reassessments, affecting Denver property taxpayers’ procedural rights.
Holding: The Court held that the Fourteenth Amendment does not require individual hearings before a general countywide property valuation increase, so the state boards’ 40% revaluation of Denver property may be enforced.
- Allows countywide property valuation increases without individual hearings.
- Owners cannot force a personal hearing before broad assessment changes.
- Distinguishes general tax rules from special assessments that need hearings.
Summary
Background
The owner of real estate in Denver sued to stop the State Board of Equalization, the Colorado Tax Commission, and the city assessor from enforcing an order that raised all taxable property values in Denver by forty percent. The State Supreme Court sustained the boards’ order and dismissed the suit. The owner argued it was not given any opportunity to be heard and that the increase would take property without due process under the Fourteenth Amendment (the Constitution’s guarantee of fair legal procedures).
Reasoning
The Court framed the central question as whether every individual must get a personal hearing before a general, countywide revaluation that treats all property owners the same. Assuming no personal hearings occurred, the Court said it is impracticable to give a direct voice to every person when a rule applies to large numbers of people. Relying on prior decisions, the Court distinguished general rules from cases where a small number of people are uniquely and individually affected — the latter can require hearings. On that basis, the Court concluded the Constitution did not require individualized hearings for this broad valuation change and affirmed the lower court’s judgment.
Real world impact
As a practical matter, state boards can order broad valuation or assessment changes affecting many property owners without holding a separate hearing for each owner, provided the change is a general rule rather than a special individual assessment. Owners who are specially and individually affected by a targeted assessment may still have a right to a hearing. The Court left state-law remedies and procedural questions to state authorities and did not address those issues here.
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