Devoe v. Missoula County

Clayton Devoe appeals a Missoula County District Court order granting the defendant Department of Revenue’s (DOR) motion to dismiss Devoe’s complaint. The dispositive issue on appeal is whether the District Court correctly ruled that appellant must exhaust his administrative remedies prior to initiating suit in district court. We affirm.

In January 1986, appellant filed a complaint in Missoula County District Court contesting the 1985 state property tax appraisal of two parcels of real property. Appellant also attacked the valuation method as discriminatory and unconstitutional. At the time he…