Open Letter to the Lafayette City Council: Do Not Renew the Arbordale Acres License Without Accountability — June 24, 2026

Submitted via the City’s online portal May 31, 2026. Published here as a matter of public record.

The following is an open letter submitted to the Lafayette CO City Council via the City’s official online portal on May 31, 2026. It is published here as a matter of public record so that the council’s receipt and the timing of notice cannot be disputed. The letter supersedes a version sent via USPS mail on May 29, 2026.

Context: Arbordale Acres Mobile Home Community in Lafayette, CO is operated by Kingsley Management Corporation of Provo, Utah. Their City of Lafayette park license (License #MHP-2025–02) expires June 24, 2026. An active eviction action against us is pending in Boulder County Court (Case #2026C031779, return date June 12, 2026). A new MHPOP complaint was filed May 29, 2026. This letter documents why the license renewal is the Council’s most direct lever for accountability, and why another renewal without conditions would continue a two-decade-long pattern of documented harm to 286 Lafayette families.**

For the narrative account of what is happening at Arbordale Acres, see our companion article here: https://medium.com/@agtialt/arbordale-acres-lafayette-co-what-the-city-council-should-ask-before-june-24-2026-f53534f0d5e0

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May 31, 2026

Lafayette City Council:

Mayor Saul Tapia Vega, Mayor Pro Tem Tim Barnes, Councilors Beaulieu, Fridland, Gallegos, Gianola, Jensen City Hall 1290 S. Public Road Lafayette, CO 80026

Re: Arbordale Acres Mobile Home Park — License #MHP-2025–02 — Urgent Request for Conditional Renewal (Expiration: June 24, 2026)

Dear Mayor Tapia Vega, Mayor Pro Tem Barnes, and Members of the City Council,

We are homeowners at Arbordale Acres Mobile Home Community (507 E. Spaulding St.), writing with an urgent request regarding the park’s license renewal. License #MHP-2025–02 expires June 24, 2026. Given the severity of the documented violations below, we request that the Council either condition the renewal or defer it pending investigation.

This is not the first time this park’s license has warranted scrutiny. In 2012, this Council conditioned Arbordale’s license renewal on Kingsley Management engaging with residents. The same patterns have returned and escalated far beyond what was documented in 2012.

SUMMARY OF DOCUMENTED VIOLATIONS

The following violations are documented with evidence, including emails, portal screenshots, billing records, video documentation, Boulder County Assessor public records, and state filings. All documentation is available to the Council upon request.

1. REFUSAL TO ACCEPT RENT (May 19, 2026)

The park stated in writing three separate times on a single evening that it will not accept our rent payment, citing disputed violation notices. On May 22, 2026, the park’s retained counsel explicitly confirmed the strategy: “No payments will be accepted until the 90-day notice is resolved to preserve the Park’s right to pursue an eviction.” The park’s own attorney has admitted in writing that they are refusing rent to manufacture grounds for eviction. There is no provision in Colorado law authorizing a park to refuse rent based on pending rule violations. Under SB21–173 (C.R.S. § 13–40–115), landlords must accept full payment at any time until a court enters judgment for possession. We have never missed a payment in six years — every bill from July 2025 through May 2026 shows $0.00 previous balance and no late fees.

The underlying Notice to Terminate Tenancy is defective on its face: it contains no date, was self-certified by the park’s own employee rather than an independent process server, and is a mass-produced Bove Law template (footer: “Bove Law Offices 6.21.24”). The park’s portal records contain notices with impossible timestamps — resolution dates that precede creation dates — indicating records are being fabricated or backdated.

2. DELIBERATE CANCELLATION OF AUTOPAY

Our autopay was established at the park office in 2020. There is no self-service option in the portal to cancel it; only park staff can make this change. We never requested cancellation. The portal then displayed a false message claiming payments “failed to process” and locked all payment functionality “for security reasons.” The portal has never included functionality to add or modify bank account information, making the “security” justification meaningless. Our bank account had sufficient funds at all times.

3. SYSTEMATIC PORTAL MANIPULATION AND RECORD DESTRUCTION

The park’s KMC resident portal has been systematically altered:

• Five years of PASSED inspection records erased (“No inspections found”)
• 50+ prior notices removed and replaced with two new notices, both pre-marked FAILED before their cure deadlines
• Billing history from June 2025 and earlier has been deleted
• Login credentials expire after a single use
• All notification settings toggled ON, but no notifications delivered in months
• Under HB24–1294, the park is required to retain payment ledgers; deletion of billing records may violate this requirement

4. RENT INCREASED WITHOUT REQUIRED NOTICE

Lot rent increased from $1,179 to $1,264/month (7.2%) in April 2026 with no written 60-day notice as required by C.R.S. § 38–12–214(1)(f.5). This is the latest in a pattern of aggressive increases: approximately $800/month in 2020 to $1,264 today — a 58% increase in six years. At $1,264/month for lot rent alone, Arbordale is not functioning as affordable housing.

Lafayette’s own 2021 Comprehensive Plan documented average lot rents in the city at $700–$800/month and noted that even at that level, “the total cost of occupying a mobile home in Lafayette, in many instances, now exceeds the average rental rate for an apartment.” At $1,264 today — 58% above the city’s own documented baseline — Arbordale is not functioning as the affordable housing the city’s Comprehensive Plan envisioned preserving.

5. VIOLATION NOTICES ON PREVIOUSLY-PASSED FEATURES

The park is citing skirting, ground cover, and porch furniture as violations — the same features that passed approximately five years of inspections. Under C.R.S. § 38–12–202(1)(b), eviction for rule violations is limited to rules “necessary to protect the health, safety, or welfare of residents.” Under HB24–1294 (C.R.S. § 38–12–214(1)), rules requiring homeowners to pay costs or restricting control over the home are presumed unreasonable unless the park proves a strict health/safety necessity. The burden is on the park.

6. SELECTIVE ENFORCEMENT

Boulder County Assessor public records show approximately 23 non-owner-occupied properties out of ~334 in Arbordale:

• 807 Quail Cv: titled to Arbordale Acres LLC (Kingsley) since 2013 — the park itself may be operating as a landlord while prohibiting homeowners from renting
• Sams Housing (Longmont): a corporate rental company owning four homes in the park
• Multiple additional LLCs, trusts, and absentee owners. Our property has been targeted for enforcement. This constitutes selective enforcement prohibited under C.R.S. § 38–12–201.5(12)(g).

7. POTENTIAL DISCRIMINATION

Our current tenants are members of the LGBTQ+ community and display a pride flag. The park’s surveillance photographs document this flag. Enforcement escalated after these tenants became visible to park staff. The park characterized them as a “threat to health and safety” — language reserved for criminal or dangerous activity. A park employee screamed profanity at the tenants through a closed door. The Colorado Anti-Discrimination Act (C.R.S. § 24–34–502) explicitly prohibits housing discrimination based on sexual orientation and gender identity.

8. SURVEILLANCE

The park’s portal contains three years of timestamped surveillance photographs of our property, including photographs taken from the back corner of the property directly outside windows. DOLA’s own published guidance (doh.colorado.gov/retaliation-is-prohibited) explicitly identifies “home owner surveillance” as a prohibited form of retaliation.

9. HARASSMENT AND COERCION

Under HB22–1287 (effective October 2022), landlords are prohibited from harassing or coercing mobile home owners. The documented pattern, 50+ violation notices since June 2021, staff confrontations with occupants, portal manipulation, and refusal to accept rent, constitutes harassment.

10. FAILURE TO PROVIDE SALE COMPLIANCE LIST

When we listed our home for sale in 2025, the park never provided the written compliance list required by C.R.S. § 38–12–214(2.5)(b). Instead, they began issuing violation notices coinciding with the listing date.

11. AT LEAST SEVENTEEN YEARS AND “THREE LEGAL MEMORANDA”

The full scope of the city's communications with and about Kingsley Management over the past 20+ years has not been publicly disclosed. We have submitted a Colorado Open Records Act request to the City of Lafayette for all communications between city officials and Kingsley Management or Arbordale Acres since 2000. That record, when produced, will tell the complete story of what the City knew and when. At a very minimum:

• 2009: Daily Camera article: “Park residents take action” (Arbordale/Kingsley)
• 2012: Lafayette City Council conditions license renewal
• 2018: City council testimony, three videos, city attorney’s “at least three legal memoranda.”
• October 2020: Colorado AG consent agreement, $146,770 restitution to residents across seven Kingsley parks, including Arbordale, for wrongful deposit withholding and improper fees.
• September 2021: The Denver Post reported 19 open complaints against Kingsley; Tom Macurdy (a longtime Arbordale resident) described the same management practices.
• 2022: Tom Macurdy litigated against Arbordale Acres LLC, Patricia Golden, Kingsley Management Corp., and Nate Nelson — Colorado Supreme Court №22SC470 (cert denied December 2022).
• 2026: CORA request to DOLA revealed at least 96 cases potentially involving these respondents over five years.
• February 2026: We filed MHPOP Case #2026–4087 (which was subsequently closed).
• May 29, 2026: We filed a new comprehensive MHPOP complaint.

We also note that in May 2018, Arbordale residents testified before this very Council about the same management practices: arbitrary enforcement of rules, fence removal without notice, rent increases, and water billing concerns. That testimony is documented publicly on YouTube

• “Lafayette CO Arbordale Mobile Home Park Landlord Injustices”
• “Testimony of Arbordale Acres Mobile Home Owners at Lafayette City Council Meeting May 15, 2018”
• “05 18 2018 Lafayette City Council Discussion of Arbordale Acres Mobile Home Park”).

The words spoken in the city’s chambers eight years ago are worth repeating here:

“The corporate owners of the land would prefer it to be a plain parking lot with homes barely attached so they can be easily removed and quickly replaced.”

“This is a community rights issue… an example of corporate rights to profits over human rights.”

“The people are tired of hearing that there’s nothing that can be done.”

“It’s like living under siege.”

Tom Macurdy, the same long-time Arbordale resident who subsequently litigated against this park operator all the way to the Colorado Supreme Court in 2022, was in that room in 2018. The council heard him then. The AG heard the residents in 2020. And now, in 2026, the same operator manages the same park in the same city, and the conduct has not only continued but escalated to refusing rent from a homeowner who has never missed a payment and to filing an eviction the day after a state complaint was filed.

The Council has seen this pattern across more than three documented inflection points: the 2018 resident testimony, the 2020 AG consent agreement, and the 2026 eviction filing.

At the 2018 meeting, when a council member mentioned that the City had sent letters to Kingsley management about residents’ concerns, Tom Macurdy responded directly: “That’s a waste of time. I know it is.” He was right then. Eight years of letters, settlements, and court cases have not changed this operator’s conduct.

A third video from a city council session held three days after the May 2018 community testimony documents city officials acknowledging that the conflict with Kingsley Group has spanned over 20 years, not 8, not 10, not 15. By that point, the city attorney had already written at least three separate revised memoranda attempting to define the city’s enforcement authority. Officials acknowledged predatory towing, water-billing abuses, fearful local staff who were unable to intervene, and discriminatory practices against vulnerable residents. The conclusion reached after three legal memoranda and 20 years of engagement: empathy for tenants, but no decisive action.

That is the record this Council inherits today. Seventeen+ years of documentation, three legal opinions, and a license renewed every year. The 2026 renewal is another opportunity to break that pattern, or to add more years to it.

The City of Lafayette has one tool that letters cannot replicate: the license. Kingsley Management has operated Arbordale Acres under a city license for over seventeen years. In those years, residents have testified before this Council, organized an HOA, litigated to the Colorado Supreme Court, prompted a state AG settlement, generated 96 DOLA complaint cases, and are now facing eviction for never missing a payment.

This is not a situation that calls for another letter. This is an over-seventeen-year license crisis that calls for a decision: do not renew until there is documented, verified compliance with the law.

The power is in your hands, and it expires June 24.

A NOTE FOR THE CITY ATTORNEY

We understand the Council relies on legal guidance when considering license conditions. We want to provide context that may be relevant to that analysis.

The park’s retained counsel, Bove Law Office, represents approximately 120 mobile home park owners across Colorado. The firm participated in drafting the MHPOP administrative rules that govern mobile home park operations statewide, serves on the Colorado Manufacturing Coalition board (the industry’s legislative lobby), and has testified before the legislature against strengthening tenant protections — including protections the legislature ultimately enacted over their objections (HB19–1309, HB22–1287, HB24–1294).

This matters to Lafayette because the firm’s expertise means the park’s conduct is not the result of ignorance. When Bove Law advises Kingsley to refuse rent — in violation of SB21–173 (C.R.S. § 13–40–115), which requires landlords to accept payment — the park cannot later claim it didn’t know the law. The violations documented in this letter are occurring with the guidance of counsel who helped write the regulatory framework.

We also wish to raise a concern we believe warrants the City Attorney’s specific attention.

Every year, the City renews this license, and new homebuyers purchase manufactured homes at Arbordale Acres. They review a lease, they review rules and regulations, but no disclosure process adequately conveys what documented public record now shows: a two decade-long pattern of arbitrary enforcement, record manipulation, rent increases without notice, refusal to accept rent, and eviction tactics designed to displace homeowners. Realtors do not disclose this. Sellers often do not know the full history. The rules and regulations document does not come close to describing the lived reality of this management.

The Lafayette City Council, however, is fully and squarely informed. This letter, the 2018 council testimony on public record, the 2020 AG consent agreement, the 96 DOLA complaint cases, the Macurdy Supreme Court litigation, and the active eviction case now before Boulder County Court, all of it is documented, public, and known to this body.

Every homebuyer at Arbordale since at least 2018 purchased into conditions the City had been warned about and chose not to act on. The City Attorney will recognize that continued license renewal, with full knowledge of this documented history and without meaningful conditions, raises questions about the City’s own potential exposure should a class of affected homeowners ever seek to examine who knew what and when.

We raise this not as a threat but as a factual observation: the City’s license implicitly endorses the operator’s fitness to manage 286 households. That endorsement now comes with a documented record. The conditions we request are the City’s most direct path to ensuring its license reflects the accountability it represents.

We also note that under DOLA’s published rules, a park may only increase rent if it “has an active registration and does not owe any penalties to MHPOP, and has complied with all final government orders.” If the park is not in compliance with state requirements, its rent increase may be unlawful regardless of notice, and the City’s license renewal would be endorsing a non-compliant operation.

HB19–1309 explicitly grants municipalities the power to enact ordinances for mobile home parks. Fort Collins City Council unanimously adopted an enhanced mobile home park licensing program on March 3, 2026 less than three months ago that includes: (1) a certified property manager requirement with city-provided training, (2) regular infrastructure assessments by the city, (3) mandatory reporting of lot rents, rent increases, and community rules, (4) city authority to abate unresolved problems and bill the park owner, and (5) annual licensing at up to $50/lot. Fort Collins framed this as an equity issue, noting that “mobile home parks are home to more underserved populations who might have less access to resources.” The measure passed unanimously.

Fort Collins adopted these conditions, knowing they would likely cause irresponsible operators to exit the market voluntarily. That is not a bug; it is a feature. Operators who cannot profitably run a real community under basic accountability standards will sell. The buyer is either a responsible operator, a resident cooperative (C.R.S. § 38–12–218 gives residents the right of first refusal), or a developer, each of which triggers its own protections for residents. The city is not being asked to displace anyone. It is being asked to set standards that responsible operators can meet, and let market forces handle the rest.

Lafayette has the same authority and an immediate opportunity, this license renewal, to exercise it. Lafayette need not start from scratch; Fort Collins has provided a template enacted three months ago that can be adapted to Lafayette’s needs.

The risk to the City of renewing this license without conditions is reputational and practical: if Kingsley’s conduct results in displacement of families from affordable housing, housing the City has licensed and implicitly endorsed, during an election year, the Council will be asked why it renewed a license for an operator with a prior AG settlement, 96 DOLA complaint cases, a Supreme Court litigation history, and documented refusal to accept rent from homeowners.

DOLA’S OWN RETALIATION CRITERIA

DOLA’s published guidance identifies the following as retaliatory actions. Every category is present in this case:

• Nonuniform rent increases ✓
• Unlawful fines, warnings, or citations ✓
• New bills or fees ✓
• Unjustified notices ✓
• Selectively enforcing rules ✓
• Threatening eviction ✓
• Home owner surveillance ✓
• Publicizing damaging information ✓

WHAT WE ARE ASKING

We are not asking the Council to adjudicate our individual dispute. That is being handled through state regulatory channels. We are asking the Council to use the one tool it has — the license renewal — to protect the 286 households at Arbordale Acres.

Specifically, we request that the Council condition the 2026 license renewal on the following. For any condition the park declines to accept, require the park to provide the City with a written explanation of why not, to be made part of the public record:

1. Lease Agreement Review and Approval The City must review and approve the lease agreement and all rules and regulations before they can be enforced against residents, or provide a written reason why not. The 2018 City Council testimony documented residents being handed new rules mid-tenancy, told they applied to them, and having no path to challenge them. This is the single most powerful preventive measure available: no surprise rules, no mid-lease amendments without City sign-off. Residents cannot be expected to fight back against terms they never agreed to and cannot afford to litigate.

**2. Immediate restoration of payment access for all homeowners**, or provide a written reason why not.

3. Written 60-day notice of all rent increases, with documentation provided to the City upon request, and automatic refund credits issued to any homeowner whose rent was increased without compliant notice, or provide a written reason why not.

4. Consistent rule enforcement across all properties, with a transparent community-wide log of all violations, inspections, and enforcement actions published on a publicly accessible website so homeowners can verify rules are being applied equally, and records cannot be selectively erased, or provide a written reason why not.

5. Certified property manager training consistent with the Fort Collins model adopted unanimously in March 2026, or provide a written reason why not.

6. Compliance reporting on all open MHPOP complaints, AG investigations, and court proceedings, or provide a written reason why not.

7. Public disclosure of all compliance records treated as public record under CORA at all times, so prospective buyers can make fully informed decisions before purchasing a home in the park, or provide a written reason why not.

CONSEQUENCES, NOT SUGGESTIONS

Each condition must carry an automatic, defined consequence for noncompliance, not referral to a complaint process (i.e., “kicking the can”), but immediate license consequences. Conditions without consequences are not conditions. They are suggestions. And this park has been absorbing suggestions for over a decade.

Specifically:

• Any rent increase implemented without a documented 60-day written notice from the City is placed in a city-held escrow account pending verification. Residents receive refunds automatically.
• Any MHPOP violation within the license year triggers a mandatory city inspection within 30 days, with findings published publicly.
• More than one MHPOP violation within a 12-month period triggers an automatic license review, not a default renewal. The city is not being asked to displace anyone. It is being asked to set standards that responsible operators can meet, and let market forces handle the rest.
• Portal or records manipulation during an active complaint triggers immediate license suspension pending a hearing.

THE LESSON OF EIGHT YEARS

Tom Macurdy stood in this chamber in 2018 with a room full of residents, documented specific violations, cited specific laws, and asked specific questions. He received polite responses, promises to look into it, and letters that went nowhere. He said it himself: “Sending letters to management is a waste of time.” He was right.

Nothing changed. The AG settled in 2020. Nothing changed. Residents litigated in the Supreme Court. Nothing changed. Ninety-six DOLA complaints were filed. Nothing changed. And now a homeowner who never missed a payment in five years has been served with an eviction notice the day after filing a state complaint, with her rent refused in writing by opposing counsel, who admitted the strategy was deliberate.

The 2018 meeting produced a panel of concerned council members, reasonable discussion, documented issues, and no accountability. No one was responsible. Nothing was required. The license was renewed. The pattern continued.

The 286 families at Arbordale Acres cannot afford another meeting that ends the same way. They deserve a council that uses the authority it actually has, i.e., the license, to require real accountability as a condition of continued operation in this city.

The license expires June 24. The power is in your hands. Use it.

NOTICE REGARDING MEDIA INTEREST

We have been contacted by Colorado journalists who have previously covered Kingsley Management and mobile home park issues in this state. We anticipate media interest in both the specific facts of this case and the broader systemic issues involving corporate park operators, including the relationship between industry counsel and the regulatory framework. We provide this notice as a courtesy so that the Council is not caught off guard.

TIMING

Arbordale’s license expires June 24, 2026. The next Council meetings are June 2 and June 16, 2026. We respectfully request that this matter be addressed at one of these meetings. We are available to speak during public comment or in any format the Council prefers.

The 286 families at Arbordale Acres in Lafayette, Colorado, deserve a park operator who follows the law, treats homeowners with respect, and operates transparently. That means a park operator that does not manufacture eviction circumstances by refusing rent, does not write notices on petty features that passed inspection for five years, does not stalk the premises with three years of surveillance photographs, does not call alternative lifestyles public safety threats, does not erase its own records when a homeowner files a complaint with the state, and does not redirect homeowners who are simply trying to pay their rent to an opposing law firm, knowing that most residents, out of fear, will call that attorney and find themselves outmatched and outspent by a firm that runs evictions across 30 counties as a business model.

These conditions are not radical. They ask only that the park do what Colorado law already requires, and that the City enforce what its own license represents.

Respectfully,

<Name withheld here, but “On behalf of ALL Arbordale Acre Residents”>

Available additional documents:

• MHPOP Complaint (new filing, May 2026)
• Certified Letter to Arbordale/Kingsley (May 22, 2026)
• Boulder County Assessor Ownership Analysis
• Billing history July 2025–May 2026
• Portal screenshots and video documentation

cc: Lynnette Beck, Lafayette City Clerk MHPOP Program Administrator Colorado Attorney General, Consumer Protection Division