Property owners have sufficient interest upon which a due process claim can arise when a municipality files a perfected utility lien against the property, as it can cloud the title and complicate the property's use and value.
As a matter of law, the minimal deprivation of property rights imposed by the lien, the relative lack of difficulty in correcting errors or monitoring third-party compliance, and the value of the gas provided satisfy the due process interests of the landlords.
http://www2.ca3.uscourts.gov/opinarch/171216p.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.