A class-action lawsuit filed by two Montana property owners alleges the Montana Department of Revenue (DOR) used illegal appraisal methods that artificially inflated property valuations statewide, forcing many taxpayers to pay more in property taxes than required by law.
Attorneys from Silverman Law Office and Edwards & Culver filed the lawsuit Feb. 2 in Madison County’s Fifth Judicial District Court on behalf of plaintiffs Lance and Lorissa Coyle and Homestead YC, LLC. The plaintiffs allege they are among thousands of Montana property owners harmed by what they describe as unlawful and inconsistent appraisal practices by the department.
Under Montana law, the Department of Revenue must reappraise properties every two years. When using the sales comparison approach to determine market value, the department is required to rely on comparable property sales occurring within six months before or after a designated assessment date.
For the 2025–2026 appraisal cycle, that assessment date was Jan. 1, 2024. The lawsuit alleges the department violated state law by using sales data outside the required 12-month window and by applying the rule inconsistently across properties, in some cases relying on sales data spanning as much as five years.
According to the complaint, the DOR relied on sales from 2019 to 2023 when valuing the Coyles’ property in Belgrade and Homestead YC, LLC’s property in Big Sky.
An independent appraiser licensed by the Montana Board of Real Estate Appraisers determined the Coyles’ Belgrade property should have been assessed at $2,296,000. The Department of Revenue, however, valued the property at $3,833,800, resulting in an estimated property tax overpayment of $12,285.
Similarly, an independent appraisal found the Big Sky property owned by Homestead YC, LLC should have been assessed at $17,509,024. The department assessed the property at $33,578,400, leading to an estimated tax overpayment of $55,804.
While Montana law allows property owners to submit independent appraisals when appealing their property valuations, those appraisals must adhere to the same 12-month valuation window imposed on taxpayers. The lawsuit argues that the department’s alleged failure to follow that rule itself undermines property owners’ ability to challenge inflated assessments.
“The Department of Revenue’s conduct is outside their legal authority,” said Joel Silverman, one of the plaintiffs’ attorneys. “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.”
The complaint asks the court to order the Department of Revenue to reassess properties statewide using lawful appraisal data, refund overpaid taxes to affected property owners, allow appeals of corrected valuations, and prohibit the department from continuing the alleged unlawful appraisal practices. If certified, the class would include all Montana property owners impacted by the disputed methods unless they choose to opt out.
The lawsuit comes amid growing concern from property owners across the state as Montana’s revised property tax system begins to take effect. While valuations may reflect rising market demand, many longtime property owners say higher assessments do not reflect their actual financial circumstances.
Several lakefront property owners who spoke with the Flathead Beacon said they are struggling to afford rising property tax bills and fear losing homes that have been in their families for generations.
Hellen Brien, a 71-year-old retiree who lives on the shore of Flathead Lake, said her property has become a source of anxiety rather than security. Her family has owned the land for decades, and she takes pride in the gardens behind her home, which bloom each summer with flowers of every color.
Brien’s grandfather passed the deed to her mother, who transferred it to Brien in 2024, according to state property records. Brien and her husband long planned to pass the property on to their daughters, making it the family’s only property in Montana and a true legacy holding.
Demand for lakefront property in Montana has surged in recent years, driving up land values across the state. As lakefront parcels grow increasingly scarce, valuations have continued to rise.
Brien said her home and buildings are now valued at $846,780 — an increase of more than $300,000 between 2023 and 2025. When combined with the land value, her total property valuation has reached $2,358,780.
Brien and her husband attempted to appeal the valuation once, she said, but the appeal resulted in an even higher assessment.
The couple’s home was originally completed in 1954 and has since been expanded to accommodate three generations of family members. The property includes a shop and garage, and the roughly two-thirds of an acre of land has been in the family since before the home was built.
As the lawsuit moves forward, its outcome could have significant implications for property taxation across Montana, particularly for longtime property owners facing sharply rising valuations and tax bills.
By BSB Staff