The $284 Million Bond Fraud Behind Arizona’s Mega Sports Complex

EvilCorporations.com • SEC v. Randall J. Miller, Chad J. Miller & Jeffrey De Laveaga • 22 min read

The Non-Financial Ledger: What Was Actually Stolen

Municipal bonds are supposed to be the boring, safe corner of investing. Pension funds park money there. Retirees park money there. Teachers, nurses, and city workers whose retirement accounts are managed by institutions park money there. Revenue bonds tied to public-benefit nonprofits carry a specific promise: the project will generate real income, and that income will flow back to the people who trusted the system enough to hand over their money.

The investors who bought Legacy Cares bonds were handed a pitch deck built on fantasy. They saw letters from what appeared to be legitimate national and international sports organizations, some of them world-renowned institutions, pledging to move entire operations and annual events to a sprawling 300-acre complex in Mesa, Arizona. They saw a peer-review study, conducted by an outside consultant, that confirmed the revenue projections. They attended a live webinar where two executives told them, on the record, that the complex was already over 90% committed before it broke ground.

None of it was real. The letters had wrong letterhead, misspelled names, and forged signatures. The “binding” pre-contracts were invented wholesale in response to the underwriter asking for more recent documentation. The peer reviewer, who was unknowing, confirmed projections built on fabricated data. Every layer of reassurance investors received was manufactured by the same small group of people who stood to profit from the bond sale.

What happened next was mechanical and inevitable. The complex opened in January 2022 with a fraction of the events promised. The revenue came in at $28 million, not $96 million. By October 2022, Legacy Cares couldn’t make its first bond payment. By May 2023, it filed for bankruptcy. The entire $284 million in investor capital was essentially gone. The Sports Complex sold for less than $26 million to a new company. Investors filed their claims and were handed back less than $2.5 million combined.

That is a recovery rate of less than one cent on the dollar. For every $1,000 a person invested in good faith, they got back approximately $8.80. Whatever you thought you were securing for your future, it was gone. And the people who took it paid themselves handsomely throughout the process.

There is no dramatic villain origin story here. This was methodical. A father and son, working alongside a COO, sat down and altered documents. They changed dates when old letters looked too stale. They forged signatures when the underwriter wanted fresher proof. They fabricated entire agreements and gave them to an underwriter who put them in front of people with real money and real lives. They did it knowingly, according to the SEC’s complaint, or at minimum with complete recklessness about the harm they were causing. When it was over, they walked away with their monthly salaries and consulting fees still deposited while investors waited in vain for their first interest payment.

Legal Receipts: What the Complaint Actually Says

The following quotes are taken directly from the SEC’s complaint, Case 1:25-cv-02702, filed April 1, 2025 in the Southern District of New York. No paraphrasing. No editorializing. These are the allegations on the record.

“The majority of the more than 50 letters of intent were either totally fabricated or materially altered in some fashion, including the forging of signatures, by Randy Miller, Chad Miller, and De Laveaga in the months leading up to the 2020 bond offering.” — SEC Complaint, Paragraph 5

• This establishes that the fraud was collaborative and premeditated, starting months before the bonds went to market, and that all three defendants personally participated in creating fake documents.
• The phrase “majority of more than 50 letters” means investors were handed a package where most of the supporting evidence was invented. The entire due-diligence foundation was rotten.

“Chad Miller falsely stated that the entire Sports Complex was pre-sold to be ‘over 90% occupancy’ by day one of opening. He further misleadingly stated that the projected revenue and occupancy rate were supported by the letters of intent—the same documents that he had helped to fabricate and alter. Similarly, De Laveaga misleadingly told investors in the webinar that the Sports Complex would be sold out before it even opened its doors.” — SEC Complaint, Paragraph 46

• Chad Miller and De Laveaga knew they had fabricated the letters when they cited those same letters on a live investor webinar in July 2020. The SEC calls this knowing or reckless conduct, meaning they either understood they were lying or had no legitimate reason to believe they were telling the truth.
• The “sold out before it opens” claim was the most aggressive sales statement and the most provably false. The complex ultimately opened to a fraction of projected demand.

“Chad Miller knowingly or recklessly fabricated, and directed the fabrication of, the pre-contracts because the dates on some of the letters of intent were stale and the Underwriter for the bonds had requested that Sports USA obtain additional communications from the purported letter writers that were more current… In response to this request, Chad Miller, with others at Sports USA working at his direction, fabricated pre-contracts with false signatures.” — SEC Complaint, Paragraph 38

• This is significant: the pre-contracts were created because a compliance request was made. The underwriter asked for fresher documentation, which is a standard safeguard. The defendants’ response was to fabricate a new layer of fraudulent documents rather than admit they didn’t have the commitments they claimed.
• The pre-contracts were described to investors as “binding” agreements. They were not binding. They were fictional.

“One fabricated letter… included a phony letterhead, misidentified the name of the sports organization that purportedly issued the letter, and misspelled the last name of the purported signatory. Another fake letter… misidentified the name of the sports organization that purportedly issued the letter, and misspelled the name of the purported signatory.” — SEC Complaint, Paragraphs 35

• The fabrications contained basic errors, wrong names, wrong letterhead, misspelled signatories. These organizations were real enough to be known commodities to potential investors, yet the defendants couldn’t spell their names correctly when forging their letters.
• The complaint notes that some letters used “incorrect letterhead from outdated sources,” meaning documents were cobbled together from old materials. This was a cut-and-paste operation, not sophisticated forgery.

“According to bankruptcy filings, the Sports Complex was ultimately sold for less than $26 million to a new company which now operates it. Due to the disappointing revenue, as well as a large number of construction and contractor liens burdening the Sports Complex, the bond investors’ bankruptcy claim recouped less than $2.5 million of the $284 million invested.” — SEC Complaint, Paragraph 54

• The $284 million raised went into construction of a complex encumbered by contractor liens, meaning the physical asset investors’ money built was delivered with pre-attached claims against it that further reduced recovery.
• The $2.5 million recovery against $284 million invested is a 99.1% loss for bondholders. This is the financial outcome of the fraud, measured in dollars.

Societal Impact Mapping

Public Health and Community Trust

Municipal bond markets fund public-benefit infrastructure across the country. This fraud struck directly at the mechanisms communities rely on for building sports facilities, transit systems, hospitals, and housing. Every institution that bought these bonds, and had to write off the loss, is an institution with fewer resources for its next project.

• The Arizona Industrial Development Authority, a state entity, served as the conduit issuer for both bond offerings. Its credibility and the credibility of similar state conduit issuers depends on the reliability of information provided by borrowers. When borrowers fabricate their documentation, the conduit structure, which is designed to expand access to capital for nonprofits, becomes a weapon against the investors it is meant to protect.
• The Sports Complex was pitched partly as a community anchor: 300 acres of sports fields, a 10,000-capacity stadium, restaurants, and entertainment in Mesa, Arizona. Hundreds of local workers in construction and eventually operations had their employment tied to an enterprise that was built on fraudulent projections. When Legacy Cares filed bankruptcy and Sports USA ceased operations, those jobs and contractor relationships dissolved.
• The bankruptcy filing revealed that the Sports Complex carried “a large number of construction and contractor liens,” meaning local subcontractors who built the facility were left as competing creditors in a liquidation proceeding. The fraud didn’t just harm Wall Street bondholders. It left Arizona construction workers and vendors trying to collect from a depleted estate.
• Public trust in municipal bonds as a safe vehicle for community investment is a collective resource. Frauds of this scale, where an entire supporting document package is fabricated end-to-end, erode the due diligence norms that keep the market functional. Increased skepticism means higher borrowing costs for legitimate nonprofits doing legitimate community work.

Economic Inequality

The $284 million raised in these bond offerings came from investors who relied on the detailed financial disclosures in the offering memoranda. The defendants extracted personal income from that pool while investors absorbed the total loss.

• The recovery rate for bondholders was less than $2.5 million on $284 million invested, roughly 0.88 cents on the dollar. Investors who bought these revenue bonds expecting to receive interest and principal from operating revenue received nothing after October 2022 and then received approximately nothing through the bankruptcy process.
• Sports USA’s fee structure, embedded in the deal from the beginning, guaranteed the defendants’ income regardless of whether the complex succeeded. Sports USA was entitled to a 5% development fee on all capital expenditures, 7% of all revenue as a basic fee, 5% of gross profits as an incentive fee, monthly accounting fees, and expense reimbursements. The defendants engineered a structure that paid them from the first dollar spent.
• Randy Miller attempted multiple prior sports park proposals over several years, each time failing to attract private financing. The shift to municipal bonds was, according to the SEC’s complaint, a deliberate strategic choice after private funding repeatedly fell through. Investors in municipal bonds expect public-benefit governance norms; the defendants exploited that expectation to sell instruments backed by fabricated commitment letters.
• Chad Miller incorporated Legacy Cares specifically as a 501(c)(3) nonprofit so a portion of the bonds could be issued as tax-exempt. The tax-exempt status reduced Legacy Cares’ borrowing cost and made the bonds more attractive to certain categories of investors, including tax-sensitive institutional buyers. The nonprofit structure was used to lower the cost of capital for a fraud.
• The peer review was conducted by an outside consultant who was unknowing. That consultant relied on the same fabricated letters of intent fed into the investor data room. A third-party seal of credibility was applied to data the defendants knew was false, giving sophisticated institutional investors a reason to treat the projections as independently verified when they were not.

The “Cost of a Life” Metric: What $281.5 Million Means

What Now: Who to Watch, Who to Contact, and What to Demand

The SEC has filed its complaint. Disgorgement, civil penalties, and a permanent bar from the securities industry are on the table. Here is who holds accountability and what you can do.

The Defendants (Named in Case 1:25-cv-02702)

• Randall J. Miller, age 70. Founder and Chairman of Legacy Sports USA, LLC. Incorporated Legacy Cares. Directed date changes on stale letters of intent. Received approximately $230,000 from bond proceeds shortly after the 2020 offering. Resident of Maricopa County, Arizona.
• Chad J. Miller, age 40. CEO of Legacy Sports USA, LLC. Son of Randy Miller. Directed fabrication of pre-contracts. Provided false documents to the underwriter. Made the “90% occupancy” claim on the July 2020 investor webinar. Paid himself more than $30,000 per month from bond proceeds. Resident of Maricopa County, Arizona.
• Jeffrey De Laveaga, age 55. COO of Legacy Sports USA, LLC. Participated in fabricating documents. Co-presenter on the July 2020 investor webinar, telling investors the complex would be “sold out before it even opens its doors.” Received more than $20,000 in consulting fees from bond proceeds. Resident of Maricopa County, Arizona.

Watchlist: Regulatory Bodies with Jurisdiction

• U.S. Securities and Exchange Commission (SEC): Primary regulator and plaintiff. The SEC’s San Francisco office brought this case. The SEC’s Municipal Securities unit monitors the $4 trillion municipal bond market. Contact: sec.gov/tcr to report tips or track case progress.
• Financial Industry Regulatory Authority (FINRA): Oversees broker-dealers and underwriters in the municipal bond market. The unnamed underwriter in this case distributed the fraudulent offering memoranda; FINRA has jurisdiction over underwriter conduct. Contact: finra.org/investors/have-problem.
• Municipal Securities Rulemaking Board (MSRB): Sets rules for the municipal securities market. This fraud exposed gaps in how conduit issuers verify borrower documentation. The MSRB accepts public comment on rulemaking: msrb.org.
• U.S. Department of Justice (DOJ): SEC civil complaints frequently result in parallel DOJ criminal referrals. Securities fraud, wire fraud, and mail fraud statutes all potentially apply here. Monitor for any parallel criminal proceedings in the Southern District of New York.
• Arizona Attorney General’s Office: Legacy Cares was an Arizona nonprofit that used the Arizona Industrial Development Authority, a state entity, to issue the bonds. The Arizona AG has authority over nonprofit and consumer protection matters. Contact: azag.gov.

What You Can Actually Do

• If you or your institution held Legacy Cares bonds from the 2020 or 2021 offerings, file a formal tip with the SEC at sec.gov/tcr. Your information can directly support the government’s disgorgement and penalty calculations against these defendants.
• Contact your municipal pension fund, union retirement fund, or local government investment office and ask whether they held Legacy Cares bonds. If they did, demand a full accounting of losses and press them on their due diligence processes.
• Advocate for stronger conduit issuer accountability in your state. Conduit issuers like the Arizona Industrial Development Authority have no legal responsibility for bond repayment; this structure allows borrowers to exploit state credibility while insulating the state from loss. Demand your state legislature require independent third-party verification of borrower documentation before conduit bonds are issued.
• Share this story with anyone who holds municipal bonds through a retirement account, municipal bond fund, or direct investment. The market’s integrity depends on investors knowing when the system has been abused.
• Support legal aid organizations in Arizona that serve construction workers and small contractors who may have filed claims in the Legacy Cares bankruptcy. Those workers built the complex; the fraud left them as creditors in a depleted estate.