these
questions to a commission or other officers the inquiry becomes judicial
and the property owner is entitled to notice or an opportunity to be
heard. Notice by publication is sufficient.[106]

EVIDENCE AND PRESUMPTION IN JUDICIAL PROCEEDINGS

Error in the admission of evidence or the entry of an erroneous judgment
after a full hearing does not constitute a denial of due process.[107] A
statute authorizing cancellation of naturalization certificates for
fraud and providing that the taking up of permanent residence abroad
within five years after naturalization shall be _prima facie_ evidence
of lack of intention to become a permanent resident of the United States
at the time of applying for citizenship was found not to be so
unreasonable as to deny due process of law.[108] Likewise, it was held
reasonable for Congress to enact that a defendant who was discovered to
be in possession of opium should be required to assume the burden of
proving that he had not obtained it through illegal importation.[109]
But a presumption that a firearm or ammunition in the possession of a
person convicted of a crime of violence was transported or received in
violation of law was held invalid because there was no rational
connections between the facts proved and that presumed.[110]

ADMINISTRATIVE PROCEEDINGS

With respect to action taken by administrative agencies the Court has
held that the demands of due process do not require a hearing at the
initial stage, or at any particular point in the proceeding so long as a
hearing is held before the final order becomes effective.[111] In Bowles
_v._ Willingham,[112] it sustained orders fixing maximum rents issued
without a hearing at any stage, saying "* * * where Congress has
provided for judicial review after the regulations or orders have been
made effective it has all that due process under the war emergency
requires."[113] But where, after consideration of charges brought
against an employer by a complaining union, the National Labor Relations
Board undertook to void an agreement between an employer and another
independent union, the latter was entitled to notice and an opportunity
to participate in the proceedings.[114] Although a taxpayer must be
afforded a fair opportunity for hearing in connection with the
collection of taxes,[115] collection by distraint of personal property
is lawful if the taxpayer is allowed a hearing thereafter.[116]

"A FAIR HEARING"

When the Co