More than 200 Montana property owners have filed a proposed class-action lawsuit challenging how the Montana Department of Revenue assessed property values in the latest appraisal cycle, alleging the agency relied on sales data outside the statutory valuation window and inflated taxable values.
The suit, brought by the Silverman Law Office, centers on residential properties in Big Sky, one of the state’s fastest-growing and most expensive real-estate markets. Plaintiffs contend the department improperly incorporated comparable sales outside the legally defined timeframe of July 1, 2023, through June 30, 2024, resulting in systematic overvaluation.
Under Montana law, property assessments are tied to market data within a specific appraisal period. The complaint argues that by drawing on transactions beyond that window, the department exceeded its authority and imposed higher tax burdens on homeowners.
Joel Silverman, chief executive of the firm, said an independent expert retained by the plaintiffs found that roughly 90% of the sampled properties were overvalued.
“It’s a little more difficult in places like Big Sky or Whitefish or other recreational areas that are very popular,” Mr. Silverman said. “The department has to try and maybe broaden its scope to find the sales data that it would like to utilize, but when they do that, the state law is very clear that the department is only supposed to use data within that time range.”
The lawsuit includes property owners who previously pursued administrative appeals of their assessments, arguing the valuations exceeded fair market value.
Rapid price appreciation in resort communities such as Big Sky and Whitefish has driven significant increases in property tax bills in recent years, fueling broader political debate over housing affordability and tax policy. Statewide reappraisals conducted by the department have drawn scrutiny as home values surged during and after the pandemic-era real-estate boom.
A ruling in favor of the plaintiffs could have financial implications for local governments that rely heavily on property-tax revenue to fund schools and public services. It could also require the department to revisit assessment methodologies in high-growth markets.
Scott Mendenhall, deputy director of the Department of Revenue, declined to comment, citing ongoing litigation.
The case is expected to proceed in state court, where judges will first consider whether the plaintiffs meet the requirements for class certification before addressing the merits of the claims.
By: DNU staff