The Colorado Court of Appeals has ruled that homeowners associations are constitutionally required to do more than serve notice of a pending foreclosure on a homeowner by mail and newspaper publication.

Martha Hummel has owned her home in Loveland, Colorado, since 1999, according to the appeals court's opinion. Her home is part of a homeowners association and comes with commensurate monthly dues. For 15 years, Hummel maintained a good relationship with her HOA. She paid her mortgage and HOA fees through an automatic monthly withdrawal from her checking account. Hummel had limited contact with the outside world and, over time, experienced a deterioration of her mental health.