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.

[1] 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, in violation of the 14th Amendment.

[2] The Supreme Court of the United States affirmed the dismissal, holding that no due process rights are implicated when a tax is levied against a large number of people who are all affected equally.

The Due Process clause of the Fourteenth Amendment provides that the government may not deprive an individual of life, liberty, or property without notice and an opportunity to be heard.

Where an agency rule will apply to a vast number of people, the Constitution does not require that each be given an opportunity to be heard directly for the purpose of arguing in favor of or against its adoption.