We believe we have documented a pattern of behavior by Colorado marijuana regulators that violates Colorado's public-trust and official-misconduct statutes, detailed below. Our conclusion rests on the enforcement comparisons, producers' recorded concerns and failures to deliver the transparency promised to the legislature. Colorado's public-trust statute, C.R.S. 24-18-103(1), requires public officials and employees to carry out their duties "for the benefit of the people of the state." Claim strength: Publisher's assessment of the record; official source for the statutory duty.
We want industry input before we submit this record to authorities. Producers, retailers and laboratories have raised concerns about testing fraud, consumer protection and enforcement at Colorado's Science & Policy Forum. This page puts our current account in one place for correction, additions and disagreement.
The focus is deliberate cheating that lets products contaminated with pesticides banned for use on cannabis reach consumers, including dilution intended to bring residues below testing action levels. We are examining the consequences for businesses that follow the rules and whether regulators' decisions served the public interest.
We are preparing material for possible district-attorney review and legislative oversight. Invited industry participants will have an opportunity to respond before any submission. No submission date is set, but it will be days, not weeks.
Send input by email or write to editor@colorado-medical-cannabis.org. You can also ask to arrange a conversation.
Compare the consequences
The clearest comparisons involve the ability to operate a business or work in the industry. The chart shows selected final license terms; each case name opens the complete note below. Fines are amounts assessed, not verified payments. A suspension held in reserve is conditional. Earlier shutdowns and other corrective measures remain part of each case's history. Claim strength: Official sources for the terms; analysis in the comparison questions.
| Case / admitted conduct | Business licenses | Owners & employees | Fine assessed |
|---|---|---|---|
| Personal consequences: payment conditions and a five-year exclusion | |||
| P2C3Microbial failures; contaminated transfersOriginal order | Business licensesTreated as revokedAlready expired | Owners & employeesTwo owners keep licenses if payments made | Fine assessed$10,000Plus taxes / interest |
| MJ DurangoUntested transfers; microbial-test handlingOriginal order | Business licensesAlready expiredDecember 2024 | Owners & employeesFive-year industry restrictionsOwnership, employment & financial interests | Fine assessed$25,000 |
| One investigation: which licenses were selected for revocation? | |||
| LevelsSelective sample treatment; contaminated transfersOriginal order | Business licensesFour surrendered; treated as revokedTwo named cultivation licenses excluded | Owners & employeesTwo owner licenses not revoked | Fine assessed$35,000 |
| ClearwaterSame investigation as LevelsOriginal order | Business licensesTwo treated as revokedAlready surrendered | Owners & employeesOwner license not revoked | Fine assessed$25,000 |
| Employee suspensions: imposed and held in reserve | |||
| CG IndustryFailed pesticides; further processingOriginal order | Business licensesNo revocation | Owners & employeesEmployee: 14-day suspensionOwner licenses not revoked | Fine assessed$15,000 |
| CSV / JoletSampling and contaminant-testing failuresOriginal order | Business licensesRevocation if fine unpaidCSV cultivation license | Owners & employeesTwo employee suspensions held in reserveOwner not suspended | Fine assessed$80,000Combined |
The question is why MED chose these different consequences. These cases have different facts and histories. The orders do not provide a complete comparative explanation of the choices, what supervisors changed, or what was verified afterward. The complete notes below preserve those distinctions and identify records that could explain them. Analysis.
All 41 orders
This review covers the 41 settlement orders in MED's posted 2026 list. They include testing, contamination, fees, taxes, ownership, inventory and other matters. Separate orders can belong to one investigation; the May and June Sixty-Six agreements settle with different groups in the same case. Some underlying allegations are incorporated by reference but missing from the posted packets.
The inability to reconstruct these decisions and their outcomes from the available public record is evidence that MED has not delivered the transparency it promised the legislature. That transparency is necessary for the public to assess whether MED applied its policies and protected consumers. Missing allegations, unexplained differences in consequences and missing verification of corrective work prevent that accountability. Claim strength: Analysis based on the orders and MED's commitments to consistent, transparent enforcement, documented decision factors and supervisory accountability. MED's response to Recommendation 2, printed pages 40–41.
Records published elsewhere could change this assessment; please point us to them.
Each note gives the original source, recorded terms, what stands out and the records that could explain it. The comparison questions are our analysis, not findings that every order was improper. Open the full list, then a case.
Read the complete review: all 41 orders
01. Golden Parachute / MR Parachute / MRW Colorado
Source order. Case 26M028; complaints 2025-0384, 0394 and 0354. Principal terms: paragraphs 17–18, pages 5–7.
Recorded conduct and terms. Official source. unpaid finally determined taxes, owner-license and eligibility failures. $10,000 plus redacted taxes; licenses surrender on day 31 if paid and are revoked on default. Owners surrender badges and face five-year bans covering ownership, passive interests, investment and employee licensing. Inventory transfer/destruction is certified. Fixed rent is expressly permitted within the terms.
What stands out. Analysis. broad personal exclusion in a case without an admitted contamination allegation, while Melody's tax-plus-testing case preserves a route to operation. This is a useful comparison, not proof of equal tax exposure or identical history.
Records that could explain this. Open questions. recommended penalty, tax/compliance history, justification for the five-year scope, earlier suspension effect, and payment and inventory records.
02. CSV CO / Jolet Ventures / 710 Labs respondents
Source order. Case 25M046; complaints 2025-0292 and 0300. Paragraphs 17–18, pages 4–7; respondent definitions earlier in order.
Recorded conduct and terms. Official source. nonrepresentative samples; CSV transfers/processing without contaminant clearance; reduced-testing failures; sampling before final form; inventory failures. $75,000 jointly against the defined business/owner group, plus Robertson and Friedenberg at $2,500 each: $80,000 assessed in total, not $75,000 per respondent. CSV loses reduced-testing privileges for at least two years. Jolet submits procedures and collector-training records. Each employee's 30-day suspension is stayed for 12 months; their payment default triggers suspension. CSV cultivation revocation is conditional on nonpayment.
What stands out. Analysis. the order does not explain why $75,000 was chosen or why it exceeds other cases. It does not allocate the amount by violation or provide mitigating/aggravating analysis. More listed violations and a longer period could matter, but are not MED's stated calculation. The owner has no immediate license suspension under these terms. Paragraph 17(d)'s lead-in begins November 14, 2024, while subpart (i) begins November 14, 2023. Those dates are inconsistent.
Records that could explain this. Open questions. original penalty calculation and revisions; accurate testing period; affected products; owners' and employees' roles; correction verification; payment; rationale for stays and the two-year reduced-testing restriction.
03. Ortiz Cannabis / Enrique Yunier Ortiz
Source order. Case 25M036; complaint 2024-0275. Paragraphs 8, 11–12, pages 2–3.
Recorded conduct and terms. Official source. September 2025 summary suspension, amended proceedings in February 2026. Facts and investigative findings are admitted by reference to the first amended order to show cause. $5,000; cultivation and owner licenses surrendered and treated as revoked; all inventory destroyed under MED supervision.
What stands out. Analysis. substantial personal and business consequences, but the posted eight-page packet omits the incorporated factual exhibit needed to know what justified them. The caption and later terms also appear to use different owner-badge numbers; verify against the licensing record before attributing a separate person or license.
Records that could explain this. Open questions. complete original/amended orders and exhibits, license identity, recommended penalty, and destruction documentation. Enrique Ortiz is a different person from Ember's Michael Anthony Ortiz.
04. Melody & Company Management
Source order. Case 26M032; complaints 2024-0306 and 2026-0033. Paragraphs 13–14, pages 3–7.
Recorded conduct and terms. Official source. sample alteration to evade testing, nonrepresentative/not-final-form sampling, undesignated collectors, transfers before contaminant clearance, missing recall-effectiveness checks, taxes, inventory and lease problems. $40,000, redacted tax payments, procedures and training. Final 30-day cultivation suspension is stayed for 12 months, with specified violation triggers; payment/tax defaults can produce automatic revocation. Earlier summary suspension began May 13, 2026.
What stands out. Analysis. admitted sample alteration and failed recall checks end with the final suspension held in reserve. The order does not explain the $40,000 selection, show recall recovery or explain the contrast with Golden's owner bans. The earlier summary suspension is real enforcement and must remain in the account.
Records that could explain this. Open questions. recall-effectiveness records, sampling evidence, lifting of the summary suspension, penalty recommendations and changes, tax/fine payments, verification of corrective work.
05. RRSA / Cutting Edge Cultivation / related respondents
Source order. Case 26M017; complaint 2025-0185. Paragraphs 14–16, pages 4–6, with ownership and prior-license history earlier.
Recorded conduct and terms. Official source. Cutting Edge/Van Dyke admit two September 2025 transfers before contaminant testing. After the approved October ownership change, RRSA/Garcia/Reger admit untagged plants and untracked marijuana. RRSA cultivation and Garcia's owner license are revoked; all inventory is to be destroyed. Van Dyke pays $1,000 and receives a five-year industry/financial-involvement ban after an earlier owner-license surrender.
What stands out. Analysis. the order separates misconduct before and after ownership changed. Reger receives no new sanction here because the order references his revocation in Ember, case 26M013. This is a concrete cross-operation link, not evidence that he trained others in cheating.
Records that could explain this. Open questions. original investigations, ownership transfer review, Reger's employment/authority at both businesses, why different personal consequences were selected, and destruction records.
06. CC Brands
Source order. Case 26M026; complaint 2025-0160. Paragraphs 11–12, pages 2–5.
Recorded conduct and terms. Official source. admitted testing circumvention, blending failed batches, untested and pesticide-failed transfers, failure to destroy after failed retests and improper batch handling. The order records CC's explanation that it believed blending permissible. $23,750; certification that retained/returned affected inventory was destroyed; revised procedures and training. No suspension or revocation.
What stands out. Analysis. consumer transfers during 2025 are described, but quantities, destinations/counts and recall recovery are redacted. Destruction of retained or returned material does not establish recovery of everything already transferred. There is no explanation of why continued licensing adequately addressed the admitted conduct or how the fine was selected.
Records that could explain this. Open questions. complete recall/recovery accounting, failed-batch histories, penalty recommendations, benefit avoided by noncompliance, correction verification, and the linked CG investigation.
07. Mariposa Medicinal Holdings
Source order. Complaint 2026-0096. Paragraphs 11–12, pages 2–3.
Recorded conduct and terms. Official source. second annual fee due February 5, 2026; four reminders; payment on May 4 after the order to show cause. $2,500, with fee receipt accepted and licenses retained.
What stands out. Analysis. the order supplies a detailed reminder and payment chronology. It is a fee case, not evidence of contaminant cheating. Compare DPM's unconditional revocation and the fee-default conditions elsewhere to assess consistent treatment.
Records that could explain this. Open questions. fee enforcement policy, prior history and reasons for this outcome relative to DPM and Jackson's.
08. High Horse
Source order. Case 26M029; complaint 2024-0034. Paragraphs 11–12, pages 2–3.
Recorded conduct and terms. Official source. transfers without required testing and without a valid reduced-testing allowance. $20,000 within 30 days; suspension if unpaid; testing/sampling procedures and collector training. No immediate license suspension or revocation for the admitted conduct.
What stands out. Analysis. the central testing failure is described briefly without dates, quantities or a consumer-product accounting. No two-year reduced-testing prohibition comparable to CSV's appears in the terms. The 2024 complaint is resolved in July 2026, without a complete intervening chronology.
Records that could explain this. Open questions. affected batches, actual contaminant results, interim restrictions, penalty basis, and training/testing verification.
09. ABCDelivery
Source order. Complaint 2025-0313. Paragraphs 8–11, pages 2–4.
Recorded conduct and terms. Official source. an October 2025 delivery compliance check used an adult ID for the online order after the system blocked a minor's ID; an underage recipient then presented her own under-21 ID, which the employee failed to check properly. The business, delivery permit and owner license had been surrendered April 4, 2026. The final terms treat the delivery permit and owner license as revoked; no fine is specified.
What stands out. Analysis. detailed incident evidence contrasts with other orders' missing narratives. Final revocation follows an earlier surrender, and the transporter license is not separately listed in the final revocation clause. The employee is described but is not a settling respondent here.
Records that could explain this. Open questions. final status of each license and any separate employee proceeding; distinguish the initial surrender from the later formal revocation. No contamination admission.
10. Sixty-Six Management, June settlement with MKHS / Kittrell
Source order. Case 24M051; complaints 2023-0352 and 2025-0156. Paragraphs 8–9, pages 3–6.
Recorded conduct and terms. Official source. undisclosed ownership/control, unlicensed interests, approval failures, security/video, tracking, manifest, records and related failures. $12,500 within 180 days; business licenses and MKHS/Kittrell licenses surrendered. Kittrell is barred from owner, passive-owner and employee participation with no end date stated.
What stands out. Analysis. this settles with a different group from the May order. It is not a duplicate PDF of that settlement. It lacks the May broad release of claims against the state. Both documents impose a $12,500 term on defined groups sharing Sixty-Six; neither supplies a payment ledger or express credit resolving their aggregate collection treatment.
Records that could explain this. Open questions. both negotiations, respondent roles, separate obligations/credits and collection, explanation of the different release terms. The orders do not establish one combined assessment or two independently collected payments.
11. Front Range Botanical / Biotech / related owners
Source order. Case 25M047; complaint 2024-0337. Paragraphs 5–16, pages 2–5.
Recorded conduct and terms. Official source. untested contaminant transfers, missing potency testing and taxes. $5,000 plus tax installments; named business and owner licenses treated as revoked; certification of prior inventory destruction. Cultivation surrendered December 5, 2024; several other interests expired or surrendered earlier. The order describes re-service in April 2026 after obtaining a new address for Goss.
What stands out. Analysis. much of the June 2026 license consequence formalizes earlier exits. Service problems explain part of the chronology; the document does not fully explain the penalty choice or prove a newly operating facility was closed in June.
Records that could explain this. Open questions. status/renewal history of each license, actual closure and destruction dates, service history, and basis for personal license treatment.
12. Medicalm Loveland
Source order. Complaint 2026-0161. Pages 1–2.
Recorded conduct and terms. Official source. an initial store application was denied May 27, 2026; the settlement approves its withdrawal. No fine or operating-product violation is stated.
What stands out. Analysis. the notice of denial is referenced as an exhibit but absent from the posted six-page packet, leaving the denial reason unavailable here. This belongs in the completeness review, not the contamination count.
Records that could explain this. Open questions. denial notice, application decision factors, and any comparable applications. The settlement terms do not identify improper treatment.
13. Top Notch Growers
Source order. Case 26M015; complaint 2024-0224. Paragraphs 8–9, pages 2–4.
Recorded conduct and terms. Official source. local/state licensing and unauthorized ownership/operation failures, including operation by a new owner before approval and missed local-approval requirements. $3,500; two business and two owner licenses surrendered. Several relevant licenses had expired earlier.
What stands out. Analysis. the chronology includes state approval and conditional approval while local licensing remained unresolved. An employee named in the caption is not part of the settling group. Compare the license exits with Verv's stayed suspension for unauthorized operations, without assuming identical facts.
Records that could explain this. Open questions. state/local approval correspondence, ownership-control evidence, the employee's separate disposition and reasons for the settlement scope.
14. Fresh Baked
Source order. Complaint 2024-0230. Paragraphs 10–12, pages 2–5.
Recorded conduct and terms. Official source. unauthorized pre-roll manufacturing at a store from January 2022 to June 2024, with some packages sold to the public without contaminant testing; giveaways; unlicensed employee activity and tracking-system access. $15,000 within 60 days and responsible-vendor training. No suspension, recall or destruction requirement appears in the settlement terms.
What stands out. Analysis. the untested products are a substantive consumer-safety admission, not merely a passing reference to reduced testing. The final remedy does not give an accounting of those products or explain why vendor training and the fine were sufficient.
Records that could explain this. Open questions. batch/product scope, consumer exposure, any separate recall, employee/owner roles and penalty reasoning.
15. Rocky Mountain Medical
Source order. Case 26M012; complaint 2024-0206. Paragraphs 13–14, pages 3–5.
Recorded conduct and terms. Official source. reused plant tags, untagged plants, missing or unreconciled inventory, use of another employee's inventory-tracking (METRC) login, and employee-list failures. $15,000 within 90 days, procedures and tracking-system training. No immediate license loss.
What stands out. Analysis. shared logins and reused tags weaken attribution and traceability, relevant to concealing conduct, but the order does not admit pesticide/sample fraud. David Kay Fisher is expressly outside this settlement rather than silently cleared.
Records that could explain this. Open questions. inventory reconciliation, authentication/access logs, Fisher's disposition, prior warnings, and why these tracking failures resulted in continued operation while other inventory cases ended in revocation.
16. BK Holdings
Source order. Complaints 2025-0339, 0341, 0342, 0343, 0344 and 2026-0082. Paragraphs 11–12, pages 3–4.
Recorded conduct and terms. Official source. unpaid second fees for multiple licenses. $10,000 within 120 days plus $13,050 fees within 30 days. Four business and two owner licenses face revocation if the fees are not paid by the deadline.
What stands out. Analysis. strong personal licensing consequences are tied to fee collection. The text includes an apparent year discrepancy in the unpaid-fee chronology; it requires source/agency clarification and should not be described as evidence of falsification.
Records that could explain this. Open questions. corrected fee chronology, per-license balances, outcome on day 31, and reasons for including owner licenses. No contaminant allegation in this settlement.
17. Xi Farms
Source order. Case 26M010; complaint 2025-0243. Paragraphs 11–12, pages 3–5.
Recorded conduct and terms. Official source. missing inventory and harvest/dry weights, transportation without a manifest, and backdated harvest batches. February 11, 2026 summary suspension. $500, increasing to $1,500 for specified failures to pay or coordinate destruction; cultivation and owner licenses revoked; all inventory destroyed under MED supervision.
What stands out. Analysis. a small dollar fine accompanies severe business and personal consequences. The fine amount alone does not capture those consequences. Backdating is relevant to traceability and possible concealment, but the settlement does not establish a contaminant-failure case.
Records that could explain this. Open questions. backdating evidence, missing inventory destinations, penalty recommendation and actual destruction; comparison with Rocky Mountain Medical and Galactic.
18. Ember / Infinite Extractions / INF COMP / Ortiz / Reger
Source order. Case 26M013; complaint 2025-0081. Paragraphs 11, 14–15, pages 3–4.
Recorded conduct and terms. Official source. factual admissions incorporate the missing order to show cause. Summary suspension February 25, 2026; $5,000 against Michael Anthony Ortiz; three business licenses, his owner license and Thomas Lee Reger's employee license revoked. Inventory was destroyed March 18. Infinite had requested surrender in July 2025.
What stands out. Analysis. serious personal consequences, but the posted packet does not reveal the incorporated underlying conduct. Reger is the same employee identified in RRSA, whose order explicitly references this revocation.
Records that could explain this. Open questions. original allegations and exhibits, employment chronology and individual responsibility, prior surrender processing, and internal recommendations. The penalty does not establish the missing allegations.
19. Frye Stop Dispensary
Source order. Complaints 2025-0372 and 0364. Paragraphs 11–12, pages 2–3.
Recorded conduct and terms. Official source. fees due November 20, 2025 remained unpaid June 1, 2026 after reminders. $3,500 within 90 days; $3,005 fees within 30 days; store and owner licenses revoked on fee default.
What stands out. Analysis. automatic consequences for unpaid fees extend to the owner; compare Mariposa's cure and DPM's unconditional revocation. The order does not supply a consistent penalty formula across those fee cases.
Records that could explain this. Open questions. payment, day-31 licensing outcome, prior history and fee-enforcement criteria. No testing/contamination admission.
20. AGG Farms
Source order. Complaint 2024-0291. Paragraphs 11–12, pages 2–5.
Recorded conduct and terms. Official source. the day after an August 2024 ownership approval, investigators found an adjacent unlicensed grow, old tags, missing security and a hole in the fence. September 2025 inspection found untagged plants and untracked marijuana; summary suspension followed. Business and owner licenses surrendered and treated as revoked; all inventory destroyed under MED supervision; no fine specified.
What stands out. Analysis. an important interval separates the earlier discoveries and later inspection. The order does not reconstruct the response during it. Strong closure/personal consequences exist even without a fine.
Records that could explain this. Open questions. August 2024 findings, intervening directions and inspections, ownership-approval review, product movement and destruction. Old Galactic tags do not by themselves establish who directed either operation.
21. CG Industry
Source order. Case 25M042; complaint 2025-0160, shared with CC. Paragraphs 9–10, pages 2–5.
Recorded conduct and terms. Official source. chlorfenapyr/myclobutanil failures in Batch A and cypermethrin in Batch B; quarantine/destruction representations followed by more testing, repackaging and remediation; July embargo and missing units. $15,000 within 120 days; destruction certification; sampling procedures/training. Employee Trujillo receives an actual 14-day suspension. The business and owners have no license revocation in these terms.
What stands out. Analysis. continued handling after MED already knew of failures is a specific escalation question. Destruction dates are January 16, 2026 for A/C/D and December 15, 2025 for B, verified from page 5. Missing units do not automatically prove sale. Why the employee receives the actual suspension while owners keep licenses is not explained by a comparative penalty analysis.
Records that could explain this. Open questions. complete batch/embargo/destruction chain, the missing units, who authorized further processing, individual responsibility and recommendations changed during settlement.
22. Sixty-Six Management, May settlement with Delos / Laue group
Source order. Case 24M051; same complaints as note 10. Paragraphs 8–10, pages 3–7.
Recorded conduct and terms. Official source. ownership/control, licensing, tracking, security and tax failures. $12,500 within 180 days; business/entity/owner and temporary-appointee license surrenders. Thomas and Karin Laue face owner/passive-owner/employee prohibitions without a stated end date.
What stands out. Analysis. paragraph 10 obtains the broad misconduct-claims release and covenant not to sue described above. Paragraph 9(c) says a release from the Division is unnecessary; the release in paragraph 10 runs to the state and officials instead. The June group does not supply the same broad release. These are distinct settlements with overlapping parties, not duplicate versions.
Records that could explain this. Open questions. release proposals, correspondence about threatened claims, involvement of Risk Management, who approved the clause and the bargain behind it; both fine obligations and collection credits. The legal protection is established; the existence of the named underlying abuses is not.
23. Jackson's Farms
Source order. Complaint 2025-0116 as captioned. Paragraphs 11–12, pages 2–3.
Recorded conduct and terms. Official source. fee due February 17, 2026 remained unpaid April 30 after reminders. $2,500 fine and $2,420 fee within 30 days; business revocation and inventory destruction on fee default.
What stands out. Analysis. the complaint number starts in 2025 while these fee facts are from 2026; seek the chronology rather than infer fabrication. Unlike BK/Frye, the owner is described without being a settling respondent. Same fine as DPM but a different route to keeping the business license.
Records that could explain this. Open questions. prior complaint history, payment, license outcome and fee policy. No contaminant allegation.
24. Magic City Farms 1
Source order. Case 26M030; complaint 2025-0191. Paragraphs 13–14, pages 3–4.
Recorded conduct and terms. Official source. pre-roll transfers to other businesses and wet whole-plant transfers to affiliated Magic City Farms 2 without contaminant testing; production batches not properly created in the tracking system. $15,000 within 30 days; updated testing procedures and collector training. No suspension, revocation, recall or destruction requirement appears in the settlement terms.
What stands out. Analysis. both testing and tracking safeguards failed across affiliated facilities, yet the order does not account publicly for where the material ultimately went or explain continued operation.
Records that could explain this. Open questions. related-facility batch histories and management, ultimate product destinations, separate recalls/holds, prior violations and penalty rationale.
25. Clearwater Consulting
Source order. Case 25M045; complaint 2024-0405, shared with Levels. Paragraphs 12–13, pages 4–6.
Recorded conduct and terms. Official source. selecting only decontaminated portions for tests; transfers of contaminated marijuana to consumers and potentially contaminated marijuana; untreated/untested shake and trim, transfers while submitted for testing, unsafe infused products and tracking/employee failures. $25,000 within 120 days; two previously surrendered operating licenses treated as revoked.
What stands out. Analysis. owner Saccomano's license is named but not revoked in the final terms. Consumer quantities are redacted. The index says May 12, while the order's approval/service dates are later in May; index dates should not override the executed document.
Records that could explain this. Open questions. owner responsibility, prior surrender dates, remaining industry interests, complete affected-product accounting, and the same investigation's Levels terms.
26. Verv
Source order. Case 25M021; complaint 2025-0163. Paragraphs 11–12, pages 3–4.
Recorded conduct and terms. Official source. unlicensed Mosaic operated/manufactured at Verv from August 2024 to July 2025 under financial and tracking-access arrangements, without required ownership/control approvals. $10,000 within 120 days; contracts terminated; 14-day business suspension stayed for one year conditioned on no further public-safety violations.
What stands out. Analysis. the posted second page is nearly blank except three black rectangles in the posted document. Unauthorized-operation consequences differ from Top Notch's license exits. This order does not admit a specific contaminant failure.
Records that could explain this. Open questions. usable page 2, original allegations, ownership/financial-interest decision history, contract termination and actual access removal, and penalty comparison.
27. Evergreen Enterprises / Rosy Refinery
Source order. Case 26M009; complaint 2025-0302. Paragraphs 13–14, pages 4–5.
Recorded conduct and terms. Official source. tax nonpayment. $2,500 plus redacted taxes within 30 days. Four business licenses and two owners' licenses already expired/surrendered in 2024 are treated as revoked. Filter's still-relevant owner suspension terminates on proof of payment; summary suspension was issued February 10, 2026.
What stands out. Analysis. most final revocations formalize older exits; the remaining owner's ability to resume depends on payment. Compare Golden's five-year prohibitions, while retaining unknown differences in taxes and history.
Records that could explain this. Open questions. actual license/operating status, payment, delay after 2024 exits, and reasons for the differing personal treatment. No contamination admission here.
28. Bona Fides Laboratory
Source order. Case 25M030; complaint 2025-0107. Paragraphs 11, 14–15, pages 3–5.
Recorded conduct and terms. Official source. pesticide/elemental-impurity methodology proceeding; admissions reference counts 1, 4, 5, 7, 8, 11, 12, 13, 14 and 15 of an underlying order absent from the posted packet. $15,000 against lab/owners; ten-day suspension stayed pending timely payment. Director Thakkar's $5,000 fine is stayed for a violation-free year. Dedicated quality-assurance and quality-control manager for two years, with reports at 6, 12 and 24 months.
What stands out. Analysis. no narrative or explanation of the disposition of the other referenced counts, and no full account of affected tests/products. The quality-management remedy is concrete and must be retained; it does not explain why personal sanctions are conditional or establish that all affected results were corrected.
Records that could explain this. Open questions. complete original counts and evidence, dropped/settled count rationale, method correction and affected-result review, quality-assurance reports, recommended sanctions and payment.
29. Levels IV / SKL Holdings III / Marchbanks / Philpott
Source order. Case 25M045; complaint 2024-0405. Paragraphs 14–15, pages 4–6; license definitions/transfer history earlier.
Recorded conduct and terms. Official source. selective decontamination of samples and consumer transfers of contaminated marijuana, with related testing/tracking failures matching the linked Clearwater proceeding. $35,000 within 120 days. Four licenses surrendered and treated as revoked: 403-00283, 403-00303, 403R-00235 and 402-00555.
What stands out. Analysis. the revocation clause omits named Monroe Street cultivation 403-01384, SKL cultivation 403R-00810 and the two owner licenses. Other store transfers are recorded earlier in the document. It is inaccurate to call this either no revocation or revocation of every named license. The order does not explain the selection or how remaining operations were assessed.
Records that could explain this. Open questions. recommendations for each license and owner, transfer approvals, management overlap, affected-product accounting and verification of remaining operations' safeguards.
30. MJ Durango
Source order. Case 25M044; complaint 2023-0040. Paragraphs 8–9, pages 3–5.
Recorded conduct and terms. Official source. 2023 untested transfers, premature/inadequate sampling, failed microbial-test handling/destruction/retesting, and tracking failures. $25,000 within 30 days; five-year restrictions covering ownership, employment, passive/indirect financial interests and consulting. Business/entity/owner licenses are described as expired December 22, 2024.
What stands out. Analysis. substantial personal exclusions in a contaminant-testing case, unlike several later license-preserving settlements. The order says reissuance is inappropriate but does not supply the comparative reasons. The final date alone does not show the business operated throughout the intervening period.
Records that could explain this. Open questions. previous orders/violations, actual shutdown, failed-batch accounting and the reason for five-year exclusion compared with CC, CSV, Levels and P2C3.
31. BD Extractions
Source order. Complaints 2025-0345 and 0346. Paragraphs 11–12, pages 2–3.
Recorded conduct and terms. Official source. two second fees due October 30, 2025 remained unpaid February 27, 2026. $4,000 within 90 days plus $4,840 fees within 30 days; two business licenses revoked on fee default. Owner described but not a settling respondent.
What stands out. Analysis. another fee-cure route, unlike DPM's unconditional revocation. No particular contaminant or corrupt-conduct evidence in these terms.
Records that could explain this. Open questions. payment, prior history and the rule for including or excluding owner-license consequences across fee cases.
32. DPM Colorado
Source order. Complaint 2025-0013 as captioned. Paragraphs 11–12, pages 2–3.
Recorded conduct and terms. Official source. second fee due December 9, 2025 remained unpaid March 11, 2026. $2,500 within 90 days and unconditional manufacturer-license revocation; remaining inventory destroyed on the specified timetable.
What stands out. Analysis. the order does not offer the pay-the-fee-and-keep-the-license route seen in Mariposa, Jackson's, BD, BK and Frye. The same dollar fine can accompany different licensing consequences. No contaminant admission.
Records that could explain this. Open questions. reason for this distinction, prior history, whether a voluntary exit was negotiated, and actual license/inventory outcome.
33. GT Infusions
Source order. Case 25M004; complaint 2024-0254. Paragraphs 13–14, pages 3–7.
Recorded conduct and terms. Official source. tracking, sampling and testing failures, including transfers without contaminant clearance alongside potency/homogeneity problems. $20,000; two manufacturer licenses surrendered and treated as revoked. Inventory was destroyed under MED supervision December 22, 2025. Feiler's one-year owner suspension is expressly February 11, 2025–February 10, 2026.
What stands out. Analysis. the stated suspension period had ended by the March 2026 settlement. Earlier summary suspension and destruction must be counted as intervention, without presenting the final order as a new year of exclusion. Schwartz's owner license is not similarly suspended/revoked in the final terms; employee Alness is described in the factual background.
Records that could explain this. Open questions. individual responsibility and any separate employee disposition, suspension history, recommended sanctions, and why the owners received different license terms.
34. Consciously Crafted / Eco Green / Greener Pasture / related respondents
Source order. Caption case 23M021; complaints 2024-0395 and 2025-0170. Paragraphs 18–20, pages 6–9; renewal footnotes earlier.
Recorded conduct and terms. Official source. important factual admissions incorporate a missing order to show cause; tax admissions are specified. Redacted taxes/interest due, with tax penalties waived for settlement. $15,000 includes an outstanding fine from a January 25, 2024 order in case 23M041. Multiple licenses are revoked, but payment opens a defined route to approval of pending Denver ownership transfers and release of held inventory. Criminal tax enforcement rights are expressly reserved.
What stands out. Analysis. the new fine includes an old unpaid obligation, so it is not all newly imposed punishment. The transfer/release provision is a negotiated benefit tied to payment; its safety and ownership basis needs examination. Timely renewal applications are expressly noted: a printed expiration does not necessarily establish an earlier closure.
Records that could explain this. Open questions. incorporated facts, prior fine/order and ledger, basis for waived tax penalties, pending transfer reviews, hold reasons and conditions for release, individual license dispositions and internal recommendations.
35. Herbal Health / Local Product
Source order. Complaint 2024-0361. Paragraphs 13–14, pages 3–4.
Recorded conduct and terms. Official source. approximately 76 tax notices since August 2023; February 10, 2026 summary suspension; taxes paid February 12 as recorded in the order. $10,000, with future tax-default surrender/revocation provisions. Criminal tax enforcement is expressly reserved.
What stands out. Analysis. the number of notices before the recorded suspension raises an escalation question. Prompt verified tax payment provides a resolution narrative absent from many consumer-product accounts. Continued licensing contrasts with Golden's bans, with unknown differences in tax amounts/history.
Records that could explain this. Open questions. what the 76 notices represented, interim action and management review, payment and lifting of the suspension, and penalty comparison. No contaminant admission here.
36. Tetra Hospitality
Source order. Case 25M041; complaint 2025-0194. Paragraph 8, pages 2–4.
Recorded conduct and terms. Official source. order to show cause referenced; terms include $15,000 within 180 days, seven-day business suspension stayed for 12 months, detailed event/vendor/employee procedures and responsible-vendor training after July 10, 2025. The terms address prohibited sale/distribution and oversight.
What stands out. Analysis. the packet has no admitted factual narrative explaining the July incident. Detailed future procedures cannot substitute for knowing what the settlement resolved. The suspension trigger includes specified future violations or payment failure and a notice/hearing process.
Records that could explain this. Open questions. underlying allegations and evidence, precise admitted/disputed facts, reasons for the stay, and verification of event controls. These terms do not establish admitted contaminant fraud.
37. I&S / Sistem
Source order. Case 25M023; complaint 2023-0331. Paragraphs 15–17, pages 3–4.
Recorded conduct and terms. Official source. March 6, 2023 patient report of a migraine after flower; the associated harvest batch lacked required microbial, pesticide and water-activity testing before transfer. $10,000 within 30 days, testing/sampling procedures and collector training. No suspension, recall or destruction requirement appears in the final terms.
What stands out. Analysis. a concrete patient complaint and untested product connect the testing lapse to a consumer-facing event, with nearly three years to final settlement. The reported symptom does not establish contamination or causation. The order does not reconstruct the affected product's disposition or the intervening response.
Records that could explain this. Open questions. original complaint and testing, batch destinations, interim action, any recall and penalty recommendations.
38. Galactic Meds / Space Buds
Source order. Complaint 2025-0125. Paragraphs 10–12, pages 2–6.
Recorded conduct and terms. Official source. May 2024–April 2025 transfers lacking required pesticide, elemental-impurity and water-activity tests, without reduced-testing eligibility; missing harvest batches; inventory-system communication failure since at least 2022; waste, patient-sales records and an eleven-day owner-license lapse. $10,000; revised procedures and a photo showing the required warning sign. No suspension or revocation in the final terms.
What stands out. Analysis. missing testing and inability to locate inventory ended with continued licensing. Batch counts and quantities are redacted, preventing exposure assessment. The order requires photographic proof of a sign but does not similarly supply a full public accounting of the missing harvests or affected products.
Records that could explain this. Open questions. missing harvest locations, untested product destinations, manual reconciliations, earlier inspection findings, penalty basis and verification that testing/traceability failures were corrected.
39. P2C3 / The Underdogs / Stipanovich / Deforest
Source order. Case 25M025; complaints 2023-0149 and 2025-0098. Paragraphs 14–15, pages 4–7.
Recorded conduct and terms. Official source. April 2023 consumer report of mold odor/taste; MED-required tests failed for yeast/mold; lapsed reduced-testing eligibility, untested/contaminated transfers, recalls and an August 2023 advisory; missing tax filings/payment. $10,000 plus redacted taxes/interest, with tax penalties waived. Expired business/entity licenses treated as revoked; two active owner licenses revoked only if taxes or the fine are not paid.
What stands out. Analysis. actual contaminant failures and consumer transfers coexist with a payment-dependent route for owners to retain industry access. Cultivation/manufacturing expired in April 2024 and the store in May 2025, so final revocation is not evidence of a new January 2026 shutdown. Redacted batch counts limit recall assessment.
Records that could explain this. Open questions. recall effectiveness, interim enforcement and operating status, basis for preserving owner licenses, tax-penalty waiver rationale, prior history and internal recommendations. Compare MJ Durango's personal bans.
40. Dutch Botanicals / Morganic Concentrates / Tran
Source order. Case 23M021 as captioned; complaints from 2022, 2023 and 2024. Paragraphs 11–13, pages 2–7.
Recorded conduct and terms. Official source. unlicensed workers/access, tracking/employee records, untested transfers and processing before contaminant clearance, excess inventory and missing collector-training records. Owner and three business licenses surrendered and treated as revoked; inventory certified destroyed; tax obligations plus a separately imposed fine whose amount is blacked out. Summary suspension was issued July 30, 2025.
What stands out. Analysis. this order includes a specific mitigation section, recording Tran's explanations about pandemic hiring, misunderstood validation requirements and corrected documentation. Those are the licensee's statements, not an express MED finding that they justified the chosen penalty. Despite that mitigation, the licenses are lost. The redacted administrative fine prevents a full comparison. Several factual/rule subparagraphs appear misaligned; the underlying order is needed to clarify the relationship between those subparagraphs.
Records that could explain this. Open questions. public fine amount and redaction authority, MED's treatment of the mitigation, complete amended orders, penalty recommendation/history and inventory destruction. The same caption number appears on Consciously Crafted despite different respondents/complaints; seek docket confirmation rather than assume a shared case.
41. Grateful Grove / Sherman
Source order. Case 25M033; complaint 2024-0327. Paragraphs 10–11, pages 2–3.
Recorded conduct and terms. Official source. all substantive facts/violations admitted through the referenced order to show cause, which is not attached in the posted seven-page packet. $30,000 within 120 days; updated sampling procedures and designated collector/training documentation. The order expressly says ordinary inventory-tracking (METRC) training does not satisfy collector training. No suspension or revocation in the terms.
What stands out. Analysis. a relatively large fine cannot be interpreted without the underlying conduct. It belongs in the testing inquiry because of the prescribed remedies, but cannot responsibly be labeled pesticide cheating on this packet alone.
Records that could explain this. Open questions. complete order to show cause and exhibits, precise admitted conduct, proposed fine and revisions, product disposition and compliance verification.
The concern we are asking you to examine
Claim strength: Analysis and investigative hypothesis. A penalty can leave cheating profitable when it costs less than the testing, destruction and lost sales that compliance requires. A failed test can then teach a business how to avoid detection on the next batch. Honest businesses bear the cost of compliance while cheaper noncompliant products can undercut their prices. This is an economic mechanism to investigate, not a measured estimate of market-wide losses. Consequences also include losing a business or the ability to work in the industry; a fine total does not capture those personal stakes.
Our concern extends to possible corruption in regulatory management: whether leaders knowingly tolerated inadequate enforcement, discouraged stronger action, pressured employees to accept decisions they believed failed to protect consumers, or used enforcement decisions to protect officials or particular interests. Whether that occurred, who was responsible and whether it violated the law are questions for investigation. The public record supplies reasons to ask; internal recommendations and communications would help establish what happened.
Dilution lowers the concentration; it does not remove the pesticide. The CC Brands order, paragraph 11(c) records the company's explanation that it blended failed batches to bring contaminants below action levels. A testing cutoff does not authorize use of a pesticide that is prohibited on the crop; Colorado sets separate criteria for pesticide use on cannabis, Part 17. Claim strength: Official sources for the recorded explanation and use criteria; analysis of the dilution mechanism.
We believe deliberately diluting pesticide-failed material to evade testing should result in license revocation, fines and jail time for the people responsible. Publisher's position on appropriate penalties.
Transparency is essential to this inquiry. The public needs to see why a response was chosen and whether its safeguards worked. A policy change and a promise to improve the next batch do not, by themselves, explain what happened to the affected products already in circulation.
What the written record establishes
An earlier audit found weak and inconsistent enforcement. In its sample of 44 identified violations, the 2023 State Auditor's report found that 26 received warnings or no action, including 23 violations affecting public safety. For 40 of the 44, the documentation did not adequately explain the different disciplinary responses. The auditor warned that failure to pursue appropriate discipline could undermine deterrence and MED's public-safety mission. This was a sample of retail investigations, not a count of contamination cases across the market. Claim strength: Official source. Audit, printed pages 33 and 39.
MED promised the legislature it would correct that pattern. In its response to Recommendation 2, MED agreed to revise severity rules and policies, identify violations unsuitable for warnings, and improve the assessment and documentation of reasons for disciplinary recommendations. It specifically committed to training and accountability measures involving leadership and supervisors. Those commitments addressed consistent, transparent enforcement and the reasons behind decisions. Claim strength: Official source. MED's response, printed pages 40–41 of the audit.
The auditor verified the reported policy changes. In January 2025, the auditor found that supporting rules, policies and procurement documents substantiated DOR's reported implementation status. These cases raise the question of whether MED followed those policies and whether they worked. Claim strength: Official source for the verification; analysis identifying the question for this review. DOR status report, auditor's conclusion.
The pattern MED promised to correct is continuing
Claim strength: Analysis based on the audit, MED's commitments and the chart and full order notes above. In our assessment, these 2026 outcomes continue the pattern of weak enforcement and insufficient public accountability that MED promised the legislature it would correct. Serious testing and safety violations repeatedly ended in settlements that preserved business or owner licenses, held sanctions in reserve, and required future procedural improvements. Other cases imposed license losses and personal bans. The public needs the reasons for those different choices and the evidence that the safeguards worked.
The connection to the audit is specific: it warned about inadequate deterrence and unexplained differences in discipline, and MED promised clearer severity standards, documented decision factors and supervisory accountability. New rules and larger fines are actions taken. They do not resolve whether the agency consistently applied those standards or verified consumer protection in these cases.
The posted settlements do not fully reconstruct the internal recommendations, changes to those recommendations and subsequent safety verification. Some omit the incorporated underlying allegations: Grateful Grove's $30,000 settlement, for example, admits facts by reference to an order to show cause absent from the posted packet. Dutch Botanicals' settlement blacks out the separately imposed administrative fine amount. These gaps prevent a complete public comparison. Records published elsewhere could change that account; please point us to them. Official sources for the packet contents; analysis of the accountability gap. Grateful Grove, paragraphs 10–11, Dutch Botanicals, paragraph 13(g).
One settlement also protects the state and its officials against claims of misconduct. The May Sixty-Six order includes a broad release covering malicious prosecution, abuse of process and constitutional claims, with a covenant not to sue over the underlying facts. The June settlement with a different respondent group in the same case lacks that broad release. Both agreements include Sixty-Six itself, so their overlapping obligations and the differences between the groups need to be examined together. The clause establishes that protection was obtained; its negotiation history could show why it was sought and whose interests it served. It does not establish that the listed misconduct occurred. The requested investigation should obtain that history alongside disciplinary recommendations and determine whether stronger action was overridden or dissent discouraged. Official sources; investigative inference. May Sixty-Six, paragraph 10, June Sixty-Six, paragraphs 8–10.
The GT Infusions settlement, paragraph 14 adds another license-loss comparison: $20,000 and manufacturer-license surrenders treated as revocations. Its inventory had been destroyed in December 2025, and the stated period of one owner's suspension had already ended by the March 2026 settlement. The earlier intervention counts; the final order should not be described as imposing a new year of suspension.
The specific statutes
Claim strength: Official sources for the law; the connection to this record is our assessment for district-attorney review. These are the statutes behind our conclusion. The district attorney should determine which provisions apply to particular officials and obtain the internal evidence needed to establish individual responsibility.
C.R.S. 24-18-103: public office is a public trust. Subsection (1) requires officials and employees to carry out their duties for the benefit of the people of Colorado. We believe the recurring weak enforcement of serious safety violations, unexplained differences in consequences and failure to deliver promised transparency violate that duty. The public cannot hold MED accountable without being able to reconstruct how its decisions protected consumers. Subsection (2) authorizes the district attorney where the trust was violated to bring appropriate judicial proceedings, in addition to any criminal action. Official text, page 277.
C.R.S. 18-8-405: second-degree official misconduct. This covers a public servant who knowingly, arbitrarily and capriciously either refrains from a duty imposed by law or violates a statute or lawfully adopted rule or regulation relating to the office. It is a petty offense. The enforcement comparisons and continuing gaps after the audit support examining whether officials knowingly disregarded their duties or the rules governing their decisions. Original recommendations, reasons for changing them and supervisory approvals would show how those choices were made. Official text, page 487.
C.R.S. 18-8-404: first-degree official misconduct. This requires intent to obtain a benefit for the official or another, or maliciously to harm another, together with a knowing unauthorized official act, failure to perform a legally imposed duty, or violation of an office-related statute or lawfully adopted rule or regulation. It is a class 1 misdemeanor. The questions here include whether decisions intentionally protected noncompliant operators or officials at the public's expense, or punished people who raised concerns. The May Sixty-Six release makes the protection obtained for the state and officials a concrete subject for that inquiry; its negotiation history is needed to determine why it was sought and what was exchanged. Official text, page 487; May Sixty-Six, paragraph 10.
C.R.S. 18-8-306: a related felony question about pressure within the department. Attempting to affect a public servant's official decision, vote, opinion or action through deceit or threats of violence or economic reprisal against a person or property, with the required intent, is a class 4 felony. The statute does not require a bribe or exempt an official who targets another official. We want investigators to determine whether those means were used to suppress stronger enforcement or silence objections. Producers' recorded concerns about retaliation supply interview leads; they do not by themselves establish a threat between regulators. The district attorney can investigate the internal communications, altered recommendations and treatment of staff who objected. Official text, page 485.
The public record is the basis for asking authorities to act. Obtaining evidence held inside the department is part of that investigation, not a condition producers or this publication must meet before requesting it.
Why independent scrutiny matters
Claim strength: Publisher's position and analysis. MED negotiated the Sixty-Six agreements with people whose business licenses and ability to work in the industry were at stake. This publication is not bargaining for those licenses or relief from those penalties. That particular source of pressure is different for an independent review.
The release contains no express prohibition on speaking publicly or cooperating with investigators, and it does not grant officials criminal immunity. Settling the licensees' claims does not explain whether the department's decisions served the public. We can ask for that explanation without requiring the owners to challenge their settlement or producers to endorse our conclusions. May Sixty-Six order, paragraphs 9–10.
Transparency is required for public accountability to work. In our assessment, the available record does not demonstrate that the promised reforms produced consistent, transparent and effective enforcement. The investigation should obtain the missing decision and verification records and determine why those results cannot be reconstructed publicly.
What industry participants have already raised
Claim strength: Accounts in machine transcripts of public meetings; the selected passages still need an audio check. These summaries describe what participants said. Their public comments do not imply endorsement of this page or a proposed referral.
- Justin Singer, February 6, 2026, about 1:32:38–1:34:46: sample adulteration creates a competitive problem and harms honest businesses and laboratories. Kevin Gallagher, about 1:37:53–1:38:33: deliberate and repeated violations need clear consequences so sanctions do not become a business expense. In its response, MED described sample adulteration as recurring and deliberate concealment of contamination as warranting its strongest penalty recommendations. February meeting.
- David Greenman, March 6, 2026, about 1:19:00–1:20:30: identifying bad actors is insufficient if they continue operating without effective consequences. MED answered that cases are considered individually and revocation should be considered where appropriate. March meeting.
- Singer, November 7, 2025, about 48:47–49:02: laboratories feared retaliatory investigations if they raised problems. This was his report of laboratories' concerns during a discussion of inconsistent test results; it was not a recorded threat by a named official. Identifying the underlying experiences matters. November meeting.
The state's recordings are available through MED's public-engagement page. Please tell us if a timestamp, attribution or description needs correction, or if a later response resolves an issue raised here.
Where your input could change this account
- Facts and missing records. Which admission, penalty, chronology or description is wrong or incomplete? Where can we find the underlying document, including a publication we missed?
- What happens after a failure. From your own experience, what happens to the affected batch, related products and subsequent testing? What distinguishes a verified correction from a change that merely avoids detection?
- The effect on honest businesses. What testing, destruction, lost sales or other costs does compliance impose? Do you have examples or records showing how competitors' conduct affected prices, customers or your operation?
- Enforcement decisions and pressure. Have you directly observed a stronger recommendation being reduced, a complaint being discouraged, or threats or adverse treatment after someone raised a concern? What happened, when, and what records or witnesses could help an investigator understand it? Please distinguish your own observations from accounts others shared.
- What effective accountability would look like. What evidence should show that destruction, recalls and corrective measures were completed? What information would let you assess whether similar violations received consistent treatment?
Input that challenges our explanation is as useful as input that supports it. A response can address one point. We are not asking anyone to join a campaign or endorse a legal conclusion.
How input will be used
Email editor@colorado-medical-cannabis.org, using the subject Contamination and enforcement review, or open an email draft. Include the passage you are addressing and any source you can share. If you prefer to talk, send a way to arrange that.
We will ask for your explicit permission before publishing or voluntarily forwarding a new private contribution, or identifying you as its source. Tell us how you would want material attributed and whether you prefer an initial conversation. Public meeting comments remain part of the public record. A lack of response will not be described as agreement.
After invited participants have had an opportunity to respond, we will evaluate corrections and additional evidence, update this page where warranted, and review the proposed authority submissions with the publisher. Participation is voluntary; no one is required to supply evidence that only an investigation can obtain.
An existing opportunity for legislative oversight
The Legislative Audit Committee approved an audit request concerning MED's enforcement of consumer-protection standards by 6–2 on March 26, 2025. The State Auditor currently lists a Marijuana Consumer Safety performance audit involving Revenue and Public Health and Environment, with release estimated for October 2026. The estimate can change. Claim strength: Official sources. Committee minutes, page 3, audits in progress.
That provides an oversight opportunity to ask whether reforms worked in actual cases. Our proposed submission would ask the auditors to examine enforcement decisions and verified consumer protection. We have not submitted this material to that audit or to a district attorney.
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