Montana Property Owners Sue State Over Illegal Tax Assessment Methods

Homeowners Claim Department Violated Its Own Rules

Montana property owners are challenging the Department of Revenue over accusations of illegally overpricing property values in a class-action lawsuit that could affect homeowners statewide . The lawsuit filed February 2 in Madison County's Fifth Judicial District Court accuses the Montana Department of Revenue of using illegal methods to artificially inflate property valuations across the state, causing many people to pay more in taxes than required .

Plaintiffs Lance and Lorissa Coyle and Homestead YC, LLC, own properties in Belgrade and Big Sky . Their cases reveal the scope of the alleged overcharging: An independent appraiser determined the Belgrade property should have been assessed at $2,296,000, but the DOR valued it at $3,833,800, causing an estimated tax overpayment of $12,285 . The Big Sky property shows even more dramatic discrepancies, with an independent appraiser concluding it should have been assessed at $17,509,024, but the DOR assigned a value of $33,578,400, resulting in an estimated tax overpayment of $55,804 .

Property taxes have been a point of concern for Montanans for years, as homeowners have seen rising valuations — and tax bills — during and after the COVID pandemic . This lawsuit addresses what attorneys call systematic violations of state law governing property assessments.

Department Accused of Breaking Assessment Timeline Rules

The heart of the legal challenge centers on timing requirements for property assessments. For the 2025–2026 appraisal cycle, Jan. 1, 2024 was designated as the assessment date, but the lawsuit alleges the department violated this requirement by using sales data outside the 12-month window and applying the rule inconsistently, in some cases using data spanning up to five years .

For the Coyles' property in Belgrade and Homestead YC, LLC's property in Big Sky, the department relied on sales spanning from 2019 to 2023 . Attorney Joel Silverman, representing the plaintiffs, said "The Department of Revenue's conduct is outside their legal authority" . He explained that "Taxpayers are confined to a strict 12-month valuation period while the department fails to follow its own rules, effectively stripping many Montanans of any meaningful ability to challenge inaccurate property valuations" .

From the 183 appeals filed during the 2025 appeal cycle, attorneys know that many other property owners are also affected by this issue . However, property owners who did not file appeals may never know whether they were impacted, because the DOR does not release its assessment data unless an appeal is filed .

Potential Statewide Impact and Remedies

The implications extend far beyond the individual plaintiffs. If the lawsuit is successful, the court would require the DOR to reassess properties statewide, and to issue refunds to anyone who overpaid on their taxes thanks to the issue . The complaint asks the court to order the DOR to reassess properties statewide using correct data, refund any overpaid taxes to taxpayers, allow taxpayers the opportunity to appeal the corrected reappraisals, and stop using unlawful appraisal practices .

If certified, the class would include all affected Montana property owners unless they opt out . The scope of Montana's property value increases adds urgency to the case. Flathead County has some of the state's most-expensive home prices, with median home values sitting at $578,000, an increase of 95% from 2020 to 2024 .

The Department of Revenue declined to comment on the pending litigation through spokesperson Jason Slead . In order to move forward as a class action, the court must first certify the class, which requires that a common policy or practice harmed a large number of people .

What This Means for Montana Homeowners

This lawsuit represents more than a technical dispute over assessment procedures. It highlights the broader challenge Montana homeowners face as property values have skyrocketed in recent years. The case could establish important precedents for how the state conducts property assessments and whether homeowners have meaningful recourse when they believe their properties have been overvalued.

For property owners wondering if they might be affected, the lawsuit's attorneys have established a contact system. Property owners with questions may contact Silverman Law Office at 406-449-4829, mtclass@mttaxlaw.com, or https://mttaxlaw.com/ . The case number is DV‑29‑2026‑