This question has been addressed in 1 Texas court opinion:
COA05 — February 5, 2026
In Messele Kelel v. Dallas Central Appraisal District, a property owner challenged a $74,250 tax valuation, presenting evidence of lower-priced comparable sales and internal settlement offers from the appraisal district as low as $30,000. The trial court granted a 'no-evidence' summary judgment in favor of the appraisal district, effectively dismissing the owner's claims. The Dallas Court of Appeals reversed this decision, ruling that the owner's evidence—specifically the comparable data and the district's own lower offers—constituted 'more than a scintilla' of evidence. The court held that while this evidence did not prove the property's value as a matter of law, it was sufficient to create a genuine issue of material fact that must be resolved at trial.
Litigation Takeaway
“To defeat a 'no-evidence' motion for summary judgment regarding property value, you do not always need a formal expert appraisal; even informal evidence like tax records, comparable sales, or internal settlement offers can meet the 'scintilla' threshold to keep your claim alive for trial.”