Due process
The Due Process protections of the 14th Amendment of the U.S. Constitution require a hearing and opportunity to be heard whenever the government wishes to violate a citizen's life, liberty, or property. Due Process rights attach to governmental activities that are adjudicative in nature, but not to activities that are legislative in nature. In the context of taxation, a legislative body has the power to tax without affording citizens due process protections. However, when the decision to tax particular individuals is made by a non-legislative body based on the individual facts and circumstances of a particular case, the decision becomes adjudicative in nature, and due process protections attach. These due process protections do not require a full trial, but the mere opportunity to file a written statement is insufficient. Due process in this context requires at least an opportunity to be heard in person and present evidence. No such opportunity was given. Therefore, the action violated Due Process, and the liens were void.