Fake Letters of Intent Behind a $284 Million Sports Park: Legacy Cares' Millers Sentenced to Prison; SEC Case Partly Settled

Published Oct. 12, 2026. Case statuses are current as of that date, based on SEC records.

The bonds were meant to be repaid from a giant new sports complex in Mesa, Arizona. According to the Securities and Exchange Commission, the revenue projections that sold them rested on fabricated documents, and the bonds defaulted within months of opening.

On April 1, 2025, the SEC charged Randall "Randy" Miller, Chad Miller and Jeffrey De Laveaga with creating false documents provided to investors in two municipal bond offerings that raised $284 million [1].

What the SEC alleged

According to the SEC's complaint, filed in the U.S. District Court for the Southern District of New York [1][2]:

• The offerings. In August 2020 and June 2021, Randy Miller's nonprofit, Legacy Cares, issued about $284 million in municipal bonds through an Arizona state entity to build a multi-sports park and family entertainment center in Mesa.
• The projections. Investors were to be paid from the complex's revenue and were shown projections several times what was needed to cover payments.
• The documents. The SEC alleged the defendants fabricated or altered the documents behind those projections, including letters of intent and contracts with sports clubs, leagues and other users.
• The result. The complex opened in January 2022 with far fewer events and much lower attendance, generated tens of millions less than projected, and the bonds defaulted in October 2022.

What has happened since

The SEC later charged a fourth person, Jeffrey Puzzullo, in a related complaint [3]. According to SEC Litigation Release No. 26498 (March 9, 2026) [3]:

• SEC case: The court entered partial judgments by consent against Randy Miller, Chad Miller and De Laveaga on July 16, 2025, and against Puzzullo on March 5, 2026. These bifurcated settlements permanently enjoin all four from violating the antifraud provisions and from participating in securities offerings other than for their own accounts. Disgorgement, interest and penalties are still to be decided by the court.
• Criminal case: Randy Miller and Chad Miller pleaded guilty and on Sept. 9, 2025, were sentenced to six and five years in prison, respectively, for securities fraud and aggravated identity theft. They were ordered to forfeit about $7.29 million and $4.80 million. On Feb. 2, 2026, they were ordered to pay restitution of about $228.3 million, jointly with each other and with Puzzullo and De Laveaga.
• De Laveaga and Puzzullo each pleaded guilty in separate criminal cases. Puzzullo was sentenced Jan. 28, 2026, to time served and one year of supervised release. De Laveaga was awaiting sentencing as of the March 2026 release. We did not find a later update on sec.gov.

"These defendants used fake documents to deceive municipal bond investors into believing a sports complex would generate more than enough revenue to make payments to bondholders," Antonia Apps, then acting deputy director of the SEC's Division of Enforcement, said in 2025 [1].

What an SEC civil case is (and isn't)

The SEC is a civil regulator. When it "charges" someone, it files a lawsuit in federal court or brings an administrative proceeding asking for remedies such as injunctions, repayment of allegedly ill-gotten gains (disgorgement), civil money penalties and industry bars. It cannot send anyone to prison. Criminal charges, when there are any, are brought separately by federal prosecutors, and a defendant in a criminal case is presumed innocent unless and until proven guilty.

Allegations in an SEC complaint are claims the agency must prove in court unless a defendant settles. When a defendant settles "without admitting or denying" the allegations, the court or the Commission enters an order, but the defendant has not conceded that the allegations are true. Throughout this article, statements about what happened are allegations or findings as described by the SEC, not established facts, unless we say a court entered a judgment or a defendant pleaded guilty.

Red flags in this case

• Revenue projections far above what's needed to repay, built on contracts you can't see.
• 'Tax-exempt' or 'municipal' labels on a deal that really depends on one private project.
• Letters of intent presented as if they were firm commitments.

How to check an investment before you hand over money

• Look up the person and the firm on Investor.gov and FINRA BrokerCheck. A clean search is not proof of legitimacy, but a missing or mismatched record is a reason to stop.
• Read the offering documents yourself, and ask a fee-only professional you found independently to read them too.
• Be skeptical of "guaranteed" or fixed high returns. Real investments carry risk, and promises of safety plus high yield are a classic warning sign.
• Be wary of pressure. Deadlines, "limited allocations" and repeated calls are sales tactics, not investment analysis.
• Don't let trust in a group replace due diligence. Fraud often spreads through churches, ethnic and professional communities, online chat groups and friends-of-friends referrals.

If you think you were affected

1. Keep everything: account statements, emails, texts, wire and payment records, and any marketing material.
2. Report it to the SEC at sec.gov/tcr. If a criminal case is involved, you can also contact the FBI at ic3.gov or the prosecutors' victim-witness office.
3. Watch for a receiver or fair fund. In some SEC cases, money is later returned to harmed investors through a court-appointed receiver or a distribution fund. Notices are posted on sec.gov.
4. Beware of "recovery" offers. People who lost money are often targeted again by scammers promising to recover it for an upfront fee. Legitimate receivers and the SEC do not charge you to file a claim.

Case status (as of Oct. 12, 2026)

Defendant	Court	Status as of Oct. 12, 2026	Source
Randall "Randy" Miller	S.D.N.Y. (SEC civil No. 1:25-cv-02702; criminal 25 Cr. 138)	Pleaded guilty; sentenced Sept. 9, 2025, to 6 years; SEC partial consent judgment July 16, 2025; SEC money remedies pending	[3]
Chad Miller	S.D.N.Y. (same)	Pleaded guilty; sentenced Sept. 9, 2025, to 5 years; SEC partial consent judgment July 16, 2025	[3]
Jeffrey De Laveaga	S.D.N.Y. (SEC civil; criminal 25 Cr. 127)	Pleaded guilty; awaiting sentencing as of March 9, 2026; SEC partial consent judgment July 16, 2025	[3]
Jeffrey Puzzullo	S.D.N.Y. (SEC civil No. 1:26-cv-01738; criminal 25 Cr. 188)	Pleaded guilty; sentenced Jan. 28, 2026, to time served; SEC partial consent judgment March 5, 2026	[3]

Statuses can change. SEC allegations are claims, not findings of wrongdoing, unless a court has ruled.

Sources

1. SEC Press Release 2025-59, "SEC Charges Three Arizona Individuals with Defrauding Investors in $284 Million Municipal Bond Offering That Financed Sports Complex," April 1, 2025. https://www.sec.gov/newsroom/press-releases/2025-59
2. SEC complaint, SEC v. Randall J. Miller et al. (S.D.N.Y.). https://www.sec.gov/files/litigation/complaints/2025/comp-pr2025-59.pdf
3. SEC Litigation Release No. 26498, "SEC Obtains Partial Consent Judgments Against Legacy Cares Defendants," March 9, 2026. https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26498

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