T1 The issue presented is whether the trial court abused its discretion in ruling that the county assessor can enter the home of a taxpayer who challenged the assessor's fair market value assessment. The fourth amendment of the United States Constitution,1 and art. 2, § 80 of the Okla. Const., protect the right of the people to be secure in their houses and effects against unreasonable searches. These protections are incorporated into 68 0.9$.2001 § 2818(C)(1) and (D)2 which prohibit the county assessor from entering the home of a taxpayer, unless the taxpayer requests a visual inspection of household personal property because its val ue is disputed. Because Oklahoma County no longer taxes household personal property there is neither a reason nor a right allowing the assessor to enter residential property. Accordingly, we hold that: 1) in the absence of a dispute over the valuation of household personal property and a request by the taxpayer, 68 0.9$.2001 $ 2818(C)(1) and (D) 3 do not authorize the County Assessor to enter residential property; and 2) 12 O.S. Supp. 2008 § 3234(A)(2) 4 of the Oklahoma Discovery Code does not provide an exception when entry to residential property is otherwise explicitly precluded by statute.
FACTS
T2 The homeowner, Joseph W. Atkinson, trustee of the Joseph W. Atkinson trust, filed a timely formal protest with the Oklahoma County Board of Equalization in 2009, challenging the fair market value assessed on his residence. The protest was denied and the homeowner sought de novo review in the District Court of Oklahoma County in May of 2009 concerning the 2009 fair market value, the taxable market value, and the gross assessed value. Thereafter, the Oklahoma County Assessor served the homeowner with a request to enter his home in order to inspect the property and take photographs pursuant to the 12 O.S8. Supp.2008 § 8234(A)(2)5 The homeowner sought a pro*358tective order relying on 68 0.8.2001 § 2818(C)(1) and (D),6 the specific statutory prohibition of inspection contained in the ad valorem tax code. The trial court denied the motion for protective order and granted the assessor's request, and the taxpayer sought relief from this Court.
I.
T3 IN THE ABSENCE OF A DISPUTE OVER THE VALUATION OF HOUSEHOLD PERSONAL PROPERTY AND A REQUEST BY THE TAXPAYER, 68 0.8.2001 § 2818(C)(1) and (D) DO NOT AUTHORIZE THE COUNTY ASSESSOR TO ENTER RESIDENTIAL PROPERTY.
14 The homeowner seeks a writ of prohibition arguing that 68 0.8.2001 § 2818(C)(1) and (D)7 prevent the trial court from ordering him to allow the assessor to enter his home. The assessor argues that because the homeowner has gone beyond an "informal" or "formal" protest that § 2818(C)(1) and (D) no longer apply. Instead, the assessor asserts that once a tax protest is appealed to district court 12 0.8. Supp.2008 § 83234(A)(2)8 of the discovery code controls. We disagree with the assessor.
T5 Contrary to the assessor's assertions, 68 0.8.2001 § 2818(C)(1) and (D)9 do not solely apply to informal and formal protests. The words "informal," "formal," and "protest" do not appear in the statute and there is no reference to disputes regarding property valuation except in the instance of a dispute regarding the valuation of household personal property. Permission to enter a home is conditioned on a dispute over valuation of household personal property. Entry to the home is based on the taxpayer's request and it is predicated on a specific statute. If there is no dispute over personalty, there is no right to enter.
T6 The fourth amendment of the United States Constitution 10 and art. 2, § 80 of the Okla. Const.11 protect a citizen's right to be free from unreasonable searches and seizures. The United States Supreme Court precedents have long recognized the fourth amendment's applicability to civil actions.12 Although this Court has never addressed the issue of whether a county assessor may enter the home of a taxpayer, some courts have permitted them to do so.13 However, *359Oklahoma's statute may provide greater protection than other states14 because of the explicit statutory prohibition against county assessors entering the homes of taxpayers pursuant to 68 00.98.2001 § 2818(C)(1) and (D).15
¶ 7 On November 3, 1992, voters elected to adopt state question 648 which amended art. 10, § 6(B) of the Okla. Const. and allowed counties the option of voting to eliminate household personal property taxes. Article 10 § 6(B) provides:
B. The board of county commissioners of any county may call a special election to determine whether or not household goods of the heads of families and livestock employed in support of the family located within the county shall be exempt from ad valorem taxation. Such an election shall also be called by the board upon petition signed by not less than twenty-five percent (25%) of the registered voters of the county. Upon passage of the question, the exemption provided for in this subsection shall become effective on January 1 of the following year.
On April 4, 1995, Oklahoma County voted on a proposition to eliminate household property tax. It stated:
Shall the household goods of the heads of families and livestock employed in support of the family located within Oklahoma County be exempt from ad valorem taxation?
The voters elected to exempt household personal property from ad valorem taxation by a vote of 85,324 to 5,765.
¶ 8 Title 68 0.S$.2001 § 2818(C)(1) and (D)16 not only describe the power and authority of the county assessor, they also provide a remedy for taxpayers involved in disputes regarding the valuation of household personal property. The language of the statute authorizes the assessor "in the performance of his duties" to inspect and appraise property in his county. However, the statute explicitly refuses to give the assessor power or authority to enter the private dwelling of a taxpayer unless the taxpayer requests it because of a "dispute concerning the valuation of household personal property." 17
¶ 9 This cause concerns a dispute over the valuation of fair market value, the taxable market value, and the gross assessed value, not a valuation of household personal property. No other statute, and neither the Oklahoma constitution nor the United States Constitution allow such governmental intrusion. Here, there is no dispute over household personal property and Oklahoma County does not collect taxes on household personal property.
¶ 10 Instead, fair market valuation of residential property is conducted pursuant to 68 § 282918 which sets forth the mass *360appraisal methodology as a process which uses known information about the property's characteristics such as location, use, size, sales price and other information from similar properties. The county assessor is required to physically visit the property every four years and, by the assessor's own admission, private residences are not entered during the valuation process.19 There is no information to be gained by entering the taxpayer's home that is necessary for a fair market valuation. Even if the inside of the taxpayer's home is lavish it is likely that the home would just be over-built for the area and the taxpayer would have invested more into the home than its fair market value.
¶ 11 Pursuant to 68 0.98.2001 § 2829(B) and (C),20 worth is dependent on known information about the property's characteristics such as location, use, size, sales price, and other information from similar properties. None of these factors involve the interior of a home because features in some homes are immeasurable in price, perhaps because they are one of a kind or very rare. This is why the mass appraisal methodology process is based on objective data which requires the analysis of multiple properties and factors.21 If those unique features were relevant, in order for them to be considered in a valuation, they would have to be compared to the unique features of comparable properties. The county assessor would have to enter every comparable home to compare interior features, which would contravene the rationale behind the fourth amendment.22
IL.
TITLE 12 0.8. Supp.2008 § 3234(A)(2) OF THE DISCOVERY CODE DOES NOT ALLOW THE COUNTY ASSESsoR TO ENTER RESIDENTIAL PROPERTY WHEN IT IS OTHERWISE EXPLICITLY PRECLUDED BY STATUTE.
¶ 13 The assessor argues that because the parties are involved in a trial, the discovery code applies to these proceedings. Just because we have a discovery code does not mean that it can be used to discover undis-coverable information. The statute, which prohibits entry into a taxpayer's home unless there is a dispute over household personal *361property, may not be transmogrified into a free-wheeling invasion of privacy. Title 12 0.8. Supp.2008 § 3234(A)(2),23 allows "entry upon designated land or other property in the possession or control of the party upon whom the request is served for the purpose of inspection and measuring, surveying, photographing, testing or sampling the property.” 24
¶ 14 It is well settled that when a court is construing seemingly conflicting statutes that a specific statute controls over one of more general applicability.25 The general discovery code does not override the statutory limits placed on the county assessor by the law. Title 68 0.$.2001 § 2818(C)(1) and (D) explicitly prohibit a county assessor from entering the home of a taxpayer unless the taxpayer requests it and it involves a dispute over the valuation of household personal property.26 The right of the Oklahoma county assessor to enter private property does not exist because Oklahoma County does not tax household personal property.27 This cause can be likened to an attempt to discover medical records to determine the extent of personal injuries when an unoccupied car is sideswiped. The statute protects the sanctity of one's home. In the absence of a challenge to household personal property and a request by the taxpayer there can be no entry.
CONCLUSION
1 15 The trial court has given the county assessor permission the law has not. The privacy afforded citizens in their homes is one of the most valued tenets of this society.28 The law goes to great efforts to protect the sanctity of a person's home and certainly more than a tax valuation should be allowed to disturb it. Because the privacy of persons in their homes is of paramount importance, we assume original jurisdiction and issue a writ of prohibition to ensure that this right remains as protected as the framers of our constitutions intended it to be.
ORIGINAL JURISDICTION ASSUMED. WRIT OF PROHIBITION GRANTED CAUSE REVERSED AND REMANDED.
COLBERT, V.C.J., KAUGER, WATT, EDMONDSON, COMBS, JJ., concur.