In the 1907 case of Londoner v. City and County of Denver, the United States Supreme Court ruled that a local tax assessment directly affecting a small group of individuals was unconstitutional because it violated due process rights under the Fourteenth Amendment. The city had imposed an assessment for street improvements on property owners in Denver without providing them with an opportunity to challenge or appeal this decision before it was made final. The court held that when a government action is not legislative in nature but instead targets specific individuals, those affected must be given notice and an opportunity to be heard - essentially, their day in court - before they can be deprived of their property. This ruling established important precedent regarding procedural due process rights at both state and federal levels.

The dissenting opinion in the Londoner v. City and County of Denver case argued that the majority's decision to grant a hearing for tax assessment disputes was unnecessary. The dissenters believed that such hearings would be impractical, burdensome, and could potentially disrupt administrative processes. They contended that as long as an individual had access to courts after an assessment was made, due process requirements were satisfied. Furthermore, they asserted that not every decision by a public body required a formal hearing; instead, written objections or other forms of protest should suffice in certain cases like this one where property owners objected to special assessments for local improvements.