Your questions, answered

You received a notice because records maintained by Jackson County indicate that you owned residential real property in Jackson County, Missouri, and paid real property taxes based on a 2023 assessed valuation that increased by more than 15% over the prior assessment cycle. On April 2, 2026, the Court certified a class action on behalf of those property owners. You previously received notice of the class action. You are now receiving a second notice because the parties have reached a proposed settlement. The Court has preliminarily approved the settlement and ordered that notice be sent so that you can learn how it affects you before the Court decides whether to give it final approval. The Notice explains the settlement, your legal rights, and your options.

The Class Representative, Nancy Wheeler, claims that any increase in residential property assessed valuations in the 2023 reassessment of more than 15% above the prior value — except increases due solely to new construction or improvements — was unlawful. The lawsuit alleges that:

• These increases resulted in a violation of Article X, Section 22(a) of the Missouri Constitution (the “Hancock Amendment”);
• These increases caused certain property taxes to be mistakenly or erroneously paid, entitling class members to statutory refunds under R.S.Mo. § 137.073;
• Defendants failed to comply with the State Tax Commission’s August 6, 2024 Order; and
• Defendants were negligent in causing and refusing to timely remedy these increases, resulting in class members incurring out-of-pocket damages.

The lawsuit seeks refunds of overpaid property taxes, additional money damages, and declaratory and injunctive relief.

The Class Representative (Counterclaim Plaintiff) is Nancy Wheeler, a Jackson County residential property owner. The Defendants (Counterclaim Defendants) include Gail McCann Beatty, in her official capacity as Assessor of Jackson County, Missouri, and other Jackson County officials and entities connected to the 2023 reassessment.

The Court has not yet entered a final judgment on any of the Class’s claims. However, the Missouri State Tax Commission issued an Order on August 6, 2024, finding that Defendants failed to provide proper notice of the 2023 reassessment and failed to perform required physical inspections for properties whose assessed values increased by more than 15%. On March 31, 2025, the Circuit Court of Jackson County upheld the State Tax Commission’s Order. Under the proposed settlement, the parties will ask the Court to resolve the Class’s claims by entering a Consent Judgment and permanent injunction. The Court will consider that request at the Fairness Hearing. If the Court approves the settlement, there will be no trial.

• October 19, 2026 — Settlement notices mailed to Class members.
• November 4, 2026 — Class Counsel files its request for attorneys’ fees, expenses, and a service award for the Class Representative. The request will be posted on the Case Documents page within two business days after it is filed.
• November 18, 2026 — Deadline to exclude yourself from the settlement or to object to it. Your request or objection must be postmarked by this date.
• November 23, 2026, 9:30 a.m. — Fairness Hearing, at which the Court will decide whether to give the settlement final approval.
• December 3, 2026 — Deadline to submit a Former Owner Claim Form or a Special-Circumstances Fund Claim Form. Claims must be submitted online or postmarked by this date.

The Court may move the Fairness Hearing without mailing another notice. Any change will be posted on this website and on the Important Dates page.

If the Court grants final approval, the settlement provides:

• Tax credits for current owners. If you still own the property, you will receive a credit equal to your full “Overage” for tax years 2023 and 2024 (explained below), applied to your Jackson County property tax bill in three annual installments. You do not need to file a claim.
• Relief for former owners. If you no longer own the property, you can submit a claim to have your Overage credited to another Jackson County residential property you own or, if you own none, paid to you in cash in three annual payments.
• Protest and appeal refunds are preserved. If you are owed a cash refund through a timely assessment appeal or because you paid under protest, you keep that right.
• A Special-Circumstances Fund of up to $6,000,000 to reimburse appraisal fees and legal fees that Class members incurred to challenge or respond to the 2023 reassessment.
• Costs paid separately. Jackson County pays the costs of notice and administration, and any attorneys’ fees, expenses, and service award the Court approves. None of those amounts reduce the credits, cash payments, or the Special-Circumstances Fund.
• Court enforcement. The County’s obligations will be set out in a Consent Judgment and permanent injunction, and the Court will keep jurisdiction to enforce them until they are fully performed.

The Overage is the amount of property tax you paid for 2023 and 2024 that was attributable to the part of your 2023 assessed valuation exceeding a 15% increase over your prior (2022) assessed valuation. It is calculated for each property from the County’s own records as follows:

• Multiply your 2022 assessed valuation by 1.15. This is your “capped” assessed valuation. It applies to 2023, and 2024 is held at the same corrected level.
• Calculate the tax that would have been owed on the capped assessed valuation, using the same tax rates actually applied to your property.
• Subtract that amount from the tax you actually paid. The result is the Overage for that year. It cannot be less than zero.
• Do this for 2023 and for 2024, and add the two years together.
• Subtract any amount already refunded to you for the same Overage through a protest or assessment appeal, and any prior correction or credit already applied for the same amounts.

The calculation is done by the County from its own assessment and tax records, using the Court-approved methodology in Exhibit C to the Settlement Agreement. Each year’s Overage belongs to the taxpayer who actually paid that year’s tax.

The Settlement Agreement includes this illustrative example. It does not represent any actual property or tax rate:

• 2022 market value: $200,000. 2023 market value before the cap: $260,000.
• 2023 capped market value ($200,000 × 1.15): $230,000, which is an assessed valuation of $43,700.
• 2023 tax as billed and paid at a combined rate of $7.50 per $100: $3,705.00. Tax at the capped valuation: $3,277.50. 2023 Overage: $427.50.
• 2024 tax as billed and paid at a combined rate of $7.65 per $100: $3,779.10. Tax at the capped valuation: $3,343.05. 2024 Overage: $436.05.
• Total Overage: $863.55, credited in three annual installments of $287.85.

You can get your estimated Overage by calling the Class Administrator toll-free at 888-969-3783. An online lookup will be added to this website. Estimates may be corrected. A correction that increases your relief can be made administratively; a methodology change that could reduce relief requires Court approval.

The Court granted preliminary approval on September 25, 2026, and entered an Amended Order on October 6, 2026 that reset the notice and deadline schedule. Preliminary approval is not final approval. It allows notice to be sent to the Class so that Class members can comment on or object to the settlement before the Court decides whether to approve it. The Court will make that decision after the Fairness Hearing on November 23, 2026.

The settlement was reached through arm’s-length mediation before the Honorable Jay A. Daugherty (Ret.). The Counterclaim Defendants assert legal and procedural defenses to the Class’s claims, and the settlement is a compromise of disputed claims. Class Counsel considered the benefits of the settlement against the risks, costs, delay, and uncertainty of continued litigation and appeal, and concluded that the settlement is fair, reasonable, adequate, and in the best interests of the Class. The Court will make its own decision on that question.

The settlement will not take effect. No one will receive credits or payments under it, no one will release any claims, and the case will return to where it stood before the settlement was reached and continue in court.

The Court certified the following Class, and the settlement applies to the same Class:

“All owners of residential real property in Jackson County, Missouri who paid real property taxes based on a 2023 assessed valuation that increased by more than fifteen percent (15%) over the prior assessment cycle, excluding increases due solely to new construction or improvements.”

The following are excluded from the Class by order of the Court:

• Defendants, including their officers and legislators;
• Counsel for the parties, including their staff and immediate family members; and
• The judicial officers assigned to this litigation, including staff and immediate family members.

You are likely a Class member if all of the following are true:

• You owned residential real property in Jackson County, Missouri during the relevant time period;
• You paid real property taxes on that property based on a 2023 assessed valuation; and
• Your 2023 assessed valuation increased by more than 15% over the prior assessment cycle, and the increase was not due solely to new construction or improvements.

If you received a mailed or emailed notice directed to you, the Class Administrator identified you as a likely Class member based on Jackson County’s records. If you are unsure, please call the Class Administrator at 888-969-3783 or contact Class Counsel at JacksonCoPropertyTaxLawsuit@hfmlegal.com.

Yes, you may still be a Class member. The certified Class definition does not exclude property owners who appealed their assessments. If you paid real property taxes based on a 2023 assessed valuation that increased by more than 15% (excluding increases due solely to new construction or improvements), you may be included — regardless of whether you filed an administrative appeal.

If you are entitled to a cash refund through a timely assessment appeal or because you paid your taxes under protest pursuant to Section 139.031, RSMo, you keep that right and will receive that refund through the County’s existing process. The settlement does not release, reduce, or delay it. To prevent double payment, your settlement relief will be reduced only by the amount actually refunded to you for the same Overage. If you receive only a partial refund, you keep the balance through the settlement. If you have questions about how your appeal or protest affects you, contact Class Counsel at JacksonCoPropertyTaxLawsuit@hfmlegal.com.

You may still be a Class member. Because the Overage is calculated from the taxes you actually paid, a reduction in your assessed valuation may reduce your Overage, and any amount already refunded to you for the same Overage will be subtracted. If you have questions about how a prior adjustment may affect you, please contact Class Counsel at JacksonCoPropertyTaxLawsuit@hfmlegal.com.

Possibly. The Class includes owners who paid real property taxes based on the 2023 assessed valuation. If you owned the property and paid those taxes, you may be a Class member even if you no longer own the property. Under the settlement you are a “Former Owner,” and you must submit a Former Owner Claim Form by December 3, 2026 to receive relief. See “Former Owners and Claim Forms” below. If you have questions about your status, please contact Class Counsel at JacksonCoPropertyTaxLawsuit@hfmlegal.com.

No. The Class is limited to owners of residential real property. The certified Class also does not include specialty parcels such as nursing homes, multi-family properties of eight or more units, tax-abated or tax-increment-financing properties, new construction, or open land. No one outside the Class receives relief or gives a release under the settlement.

Nothing. If the settlement is approved, your credit will be applied automatically. You do not need to submit a claim form, application, or proof of any kind.

Your total Overage will be credited against the Jackson County real property tax bill for your property in three substantially equal annual installments.

The installments will be applied to your 2026, 2027, and 2028 tax bills.

Yes. Pay your tax bill as issued and on time. Do not reduce your payment in anticipation of a settlement credit. Credits will be applied only as the Court orders.

Any unused portion of an installment carries forward to the next year, and continues to carry forward until the full credit has been applied. The credit does not expire after the 2028 tax year if any portion remains.

No. The County may not offset your credit against unrelated debts, fines, fees, or other amounts it claims you owe, unless a separate court order requires it.

Contact the Class Administrator at 888-969-3783 or Class Counsel at JacksonCoPropertyTaxLawsuit@hfmlegal.com. Class Counsel and the Settlement Administrator have access to the County’s implementation records to look into Class members’ questions about the accuracy of their credits, and the County must promptly correct confirmed errors and pay any amount it under-credited.

The credit belongs to the taxpayer who paid the Overage, not to a later buyer. If you own another residential property in Jackson County, you may ask the Settlement Administrator to apply your remaining credit to that property. If you sell, contact the Class Administrator at 888-969-3783.

No. If a mortgage servicer or escrow agent paid your taxes from your escrow account, you are treated as the taxpayer who paid them, and the credit or payment belongs to you. How a credit on your tax bill affects your escrow account is between you and your mortgage servicer.

A Former Owner is a Class member who, as of October 19, 2026 (the Notice Date), no longer owns the property that was taxed in 2023 and/or 2024 — for example, because of a sale, transfer, foreclosure, tax sale, or death.

• If you own another residential property in Jackson County: your Overage will be credited to that property’s County tax bill on the same three-year schedule as other credits. The other property does not have to be titled exactly the same way, as long as you show it is owned by the same taxpayer (for example, through your trust).
• If you own no residential property in Jackson County: your Overage will be paid to you in cash, in three annual payments. These payments are funded separately by the County and are not taken from or limited by the Special-Circumstances Fund.

In either case, you must submit a Former Owner Claim Form by December 3, 2026.

Complete and sign the claim form and submit it by December 3, 2026 in any of these ways:

• Online at wheelerbeatty.claims-administrator.com
• By email to JacksonCoPropertyTaxLawsuit@hfmlegal.com
• By mail, postmarked by December 3, 2026, to:

Copies of the Former Owner Claim Form and the Special-Circumstances Fund Claim Form are available on the Case Documents page and from the Class Administrator at 888-969-3783.

For a Former Owner claim, a signed claim form made under penalty of perjury is generally enough. You may include documents, such as a closing statement or tax receipt, which may speed processing, but they are not required unless the Settlement Administrator has reason to question the claim. The Administrator may not impose technical requirements that would defeat an otherwise valid claim.

Yes. The estate, personal representative, heir, trustee, or successor of a deceased Class member is entitled to the relief the Class member would have received, upon reasonable proof of authority. Use the deceased-owner section of the Former Owner Claim Form, or contact the Class Administrator at 888-969-3783.

If your claim has a problem that can be fixed, the Settlement Administrator must notify you in writing and give you at least 21 days to fix it before denying the claim. If a claim is denied, you will be told why. You may ask for review of the denial within 14 days, and you will receive a written decision.

The Settlement Administrator may accept a late claim for good cause shown before final distribution, but you should not rely on that. Submit your claim on time.

It is a fund of up to $6,000,000 paid by Jackson County to reimburse Class members for certain costs they incurred to challenge or respond to the 2023 reassessment and the resulting 2023 and 2024 taxes. It is separate from, and in addition to, the tax credits and Former Owner cash payments.

• Appraisal fees you paid to challenge or respond to the 2023 reassessment and the resulting 2023 and 2024 taxes;
• Legal fees you paid for that purpose; and
• Attorney’s fees you owe under a contingent-fee agreement for that purpose that you signed before July 8, 2026.

Each expense must be supported by documentation and must have been caused by the 2023 reassessment. The Fund does not pay speculative, punitive, emotional-distress, reputational, or duplicative damages.

If you owe attorney’s fees under a contingent-fee agreement signed before July 8, 2026 check “Legal fee,” write “contingent fee” in the description, and attach the fee agreement.

An independent Special-Circumstances Fund Administrator appointed by the Court, the Honorable J. Dale Youngs (Ret.), decides each claim under a Court-approved Claims Protocol. The County does not decide claims and is prohibited from influencing the outcome of any claim. The same notice, cure, and review procedures that apply to Former Owner claims apply to Fund claims.

There is no per-claim cap. If the total of approved claims is more than $6,000,000, every approved claim will be reduced proportionally.

After all approved claims, reviews, taxes, and Fund administration expenses are paid, any remaining amount goes back to the County, but only after the Administrator files a final accounting and the Court authorizes closing the Fund.

Submit a Special-Circumstances Fund Claim Form, with documentation of your expenses (such as invoices, receipts, engagement letters, or fee agreements, and proof of payment where applicable), by December 3, 2026, using any of the methods described under “How do I submit a claim form?” above.

Yes. Current owners who receive automatic credits and Former Owners who submit a Former Owner Claim Form may also submit a Special-Circumstances Fund claim if they have eligible expenses.

Approved claims will be paid as soon as reasonably practicable after the settlement becomes effective and all claims have been finally determined.

Your options under the settlement are:

• Do nothing. If you still own the property, you will receive your credit automatically. You will remain in the Class and be bound by the Court’s judgment.
• Submit a claim by December 3, 2026. Required if you are a Former Owner, or if you want reimbursement from the Special-Circumstances Fund.
• Exclude yourself by November 18, 2026. You will receive no credit or payment under the settlement, and you will keep any right to bring your own lawsuit on the monetary claims.
• Object by November 18, 2026. Tell the Court what you do not like about the settlement or the fee request. You must remain in the Class to object.
• Attend the Fairness Hearing on November 23, 2026. Attendance is optional.

No. The Court certified certain claims for declaratory and injunctive relief under Missouri Rule of Civil Procedure 52.08(b)(2). Those claims apply to all Class members, and you cannot opt out of them. However, you may request exclusion from the claims seeking monetary relief (such as tax refunds and negligence damages) that were certified under Rule 52.08(b)(3).

To exclude yourself, you must mail a written request for exclusion. Your letter must include:

• The name of the lawsuit: Wheeler v. Beatty, et al., Case No. 2416-CV25478;
• A clear statement that you wish to be excluded from the settlement;
• Your full name and address;
• The address of the affected property; and
• Your signature.

Send your letter by U.S. mail to:

Your letter must be postmarked no later than November 18, 2026. If you miss the deadline, you will remain in the Class and be bound by the settlement and the Court’s judgment if the settlement is approved.

If you exclude yourself, you will not receive a tax credit, Former Owner payment, or Special-Circumstances Fund payment, and you will not be bound by the settlement’s release of the monetary claims. You will no longer be a member of the class for purposes of the monetary claims, which means you will no longer be represented by Class Counsel, but you will keep any right to bring your own lawsuit on the monetary claims.

If you do not exclude yourself, you may object to the settlement, to Class Counsel’s request for attorneys’ fees and expenses, or to the service award. Your objection must be in writing, postmarked by November 18, 2026, and include:

• Your name and address;
• Your parcel number or other information sufficient to confirm you are a Class member;
• The reasons for your objection;
• Whether your objection applies only to you, to a specific group of Class members, or to the entire Class; and
• Whether you intend to appear at the Fairness Hearing, either by yourself or through a lawyer.

Do not include your Social Security number. Mail your objection to the Settlement Administrator, postmarked by November 18, 2026:

Objecting tells the Court you disagree with something about the settlement. You stay in the Class, and if the settlement is approved you receive its benefits and are bound by it. Excluding yourself means you are no longer part of the settlement: you receive no benefits under it, are not bound by its release of the monetary claims, and cannot object. If you exclude yourself, you will no longer be a member of the class for purposes of the monetary claims, which means you will no longer be represented by Class Counsel, but you will keep any right to bring your own lawsuit on the monetary claims.

If you do nothing, you will remain a member of the Class. You will be bound by the settlement and the Court’s judgment if the settlement is approved. You will not be personally responsible for Class Counsel’s fees or costs. If you still own the property, you will receive your credit automatically. If you are a Former Owner, you will not receive a credit or payment unless you submit a claim form by December 3, 2026.

No. Class members do not personally pay Class Counsel’s attorneys’ fees or litigation costs. Any fees and expenses the Court awards will be paid by Jackson County separately and will not reduce your credit or payment. See “The Lawyers and Their Fees” below.

Yes. You may retain your own attorney at your own expense. However, Class Counsel will continue to represent the Class as a whole. Having your own lawyer does not remove you from the Class. Your lawyer may appear at the Fairness Hearing on your behalf.

Unless you exclude yourself, you will release Jackson County, the Jackson County Board of Equalization, the Jackson County Department of Collections, Gail McCann Beatty, Frank White, Jr., and Phil LeVota, and their present and former officials, officers, employees, agents, attorneys, insurers, and representatives in their capacities relating to these claims, from the claims asserted in this lawsuit and claims that could have been asserted based on the same facts. These are claims arising from the County’s 2023 and 2024 residential reassessment, valuation increases, inspection practices, notices, tax levies, and collection of the resulting Overage, including claims under the Hancock Amendment, Section 137.073, RSMo, mandamus, declaratory judgment, negligence, and related state-law theories. The release covers both known and unknown claims based on those facts, but not a materially different injury or transaction.

• Your right to enforce the settlement and the Court’s judgment;
• Your right to a cash refund through a timely assessment appeal or payment under protest;
• Claims unrelated to the 2023 and 2024 reassessment; and
• Claims based on conduct that occurs after the settlement becomes effective.

The release does not take effect for any category of relief until that relief has been paid or performed. Even after the release takes effect, the Class keeps all rights needed to make the County fully perform the settlement.

On April 2, 2026, the Court appointed the following attorneys from Humphrey, Farrington & McClain, P.C. as Class Counsel:

• Kenneth B. McClain
• Jonathan M. Soper
• Nichelle L. Oxley

Their law firm is:

You will not be charged for these lawyers.

Class Counsel will ask the Court to award attorneys’ fees and litigation expenses in a combined amount of no more than $4,000,000, and a service award of $5,000 to Class Representative Nancy Wheeler for her work on behalf of the Class. Jackson County has reserved the right to argue for a lower amount. The Court will decide how much to award.

Whatever the Court awards will be paid by Jackson County separately and in addition to the Class’s relief. No part of the credits, Former Owner payments, or Special-Circumstances Fund will be used to pay it, and a reduction or denial of the fee request will not end the settlement or delay Class relief.

Class Counsel will file the fee request by November 4, 2026, and it will be posted on the Case Documents page within two business days, before the November 18 objection deadline.

The Court will hold the Fairness Hearing on November 23, 2026 at 9:30 a.m. in Division 60 of the Circuit Court of Jackson County, Missouri, at Kansas City before the Honorable Jacqueline A. Cook. The Court will consider whether to approve the settlement, any objections, Class Counsel’s request for fees and expenses and the service award, and entry of the Consent Judgment.

The hearing may be moved to a later date without another mailed notice. Check this website before attending.

No. Class Counsel will answer any questions the Court has. You may attend at your own expense. If you submit a timely written objection, the Court will consider it whether or not you attend.

If you submit a timely objection, you may ask to speak at the hearing, either as yourself or through your own lawyer. State in your objection that you intend to appear.

A class action is a lawsuit in which one or more plaintiffs (the “Class Representatives”) sue on behalf of a larger group of people who have similar claims. The members of that group are called the Class. In a class action, the Class Representatives and Class Counsel act on behalf of all Class members. A decision by the Court — whether it favors the Class or the Defendants — generally binds all Class members, except those who properly exclude themselves from claims where exclusion is permitted.

Key developments include:

• August 6, 2024: The Missouri State Tax Commission issued an Order finding that Defendants failed to provide proper notice of the 2023 reassessment and failed to perform required physical inspections for properties whose assessed values increased by more than 15%.
• March 31, 2025: The Circuit Court of Jackson County entered Judgment upholding the State Tax Commission’s August 6, 2024 Order.
• April 2, 2026: The Court entered an Order certifying the Class under Missouri Rule of Civil Procedure 52.08(b)(2) and (b)(3) and appointing Ms. Wheeler as Class Representative and Humphrey, Farrington & McClain, P.C. as Class Counsel.
• July 8, 2026: Following mediation before the Honorable Jay A. Daugherty (Ret.), the parties signed a binding settlement term sheet.
• July 10, 2026: The deadline to request exclusion from the certified Class passed; however under the terms of the settlement, all class members are given a second chance to exclude themselves by November 18, 2026.
• August 24, 2026: The parties entered into the Class Action Settlement Agreement and Release.
• September 25, 2026: The Court granted preliminary approval of the settlement.
• October 6, 2026: The Court entered an Amended Order setting the current schedule, including the November 23, 2026 Fairness Hearing, and stayed all other litigation pending that hearing.

All other litigation, including the trial, is on hold pending the Fairness Hearing on November 23, 2026. If the Court approves the settlement, it will enter a Consent Judgment. The settlement becomes effective once that judgment is final — when the time to appeal has passed without an appeal, or when any appeal is resolved. Credits and payments begin after that, as described above.

Settlement relief depends on the Court granting final approval and the judgment becoming final. If that happens, current owners receive credits automatically, and Former Owners and Special-Circumstances Fund claimants receive relief on approved, timely claims. If your Overage is zero — for example, because your assessment was reduced or your taxes were already fully refunded — you will not receive a credit.

If you still own the property, no. You will remain in the Class and receive your credit automatically if the settlement is approved. If you are a Former Owner, or if you want reimbursement from the Special-Circumstances Fund, you must submit a claim form by December 3, 2026. However, if your address or contact information changes, please notify the Class Administrator so that you can continue to receive important updates and notices.

You may update your address or contact information by contacting the Class Administrator:

A few select documents are posted on the Case Documents page, including the Settlement Notice, the Settlement Agreement, the claim forms, the Court’s preliminary approval order, and, once filed, Class Counsel’s request for fees and expenses.

All additional Court filings are available through the Missouri CaseNet system at courts.mo.gov/casenet. You can search for this case by its Case Number: 2416-CV25478.

No. Please do not contact the Court or any of the Defendants, including Jackson County, with questions about this lawsuit or the settlement. Direct all questions to Class Counsel or the Class Administrator using the contact information above.

The parties and their lawyers cannot give you tax advice. If you have questions about tax consequences, consult your own tax advisor.

For additional information, you may:

• Contact Class Counsel at JacksonCoPropertyTaxLawsuit@hfmlegal.com or contact the Class Administrator by telephone at 888-969-3783;
• Review Court filings on Missouri CaseNet at courts.mo.gov/casenet under Case No. 2416-CV25478; and
• Review the Notice of Proposed Class Action Settlement you received and the Settlement Agreement, available on the Case Documents page.