Which case emphasizes the need for a "separate" hearing before fines and liens are imposed?

The case that emphasizes the need for a "separate" hearing before imposing fines and liens is Massey and Massey v. Charlotte County. This case is significant because it highlights due process considerations in the enforcement of code violations. In matters of code enforcement, property owners must be afforded the opportunity to contest allegations before penalties are levied. This case established a precedent that local governments are required to provide a meaningful hearing where individuals can present their side and challenge the evidence against them before any fines or liens are finalized.

The significance of this ruling lies in its reinforcement of fairness in the administrative process. By ensuring that a separate hearing occurs prior to penalties, the judiciary emphasizes the importance of due process in government actions against property owners, setting a standard that local enforcement agencies must adhere to in order to uphold constitutional rights. This sets a clear expectation that mere accusation is not sufficient for the imposition of financial penalties without first allowing an opportunity to dispute those claims.