Homeowners in Okaloosa County challenged their 1995 property tax bill under a recent Florida constitutional amendment capping annual tax increases at 3%. The property appraiser contended that portions of their property, through oversight or mistake, had escaped taxation in prior years, and the increases merely reflected a more accurate appraisal. He argued that a Florida statute gave him authority to increase assessments in this manner despite the 3% cap. The homeowners argue that the higher assessments violate the 3% cap and that the statute is unconstitutional. The trial court agreed with the homeowners, and on appeal the First District Court affirmed the ruling. The property appraiser appeals.