Four Buildings, 23 Leases, Zero Disclosures

Dennis Meints is a sole proprietor who rented residential housing in St. Paul, Minnesota. Every building he owned was constructed before 1978. That single fact triggers a specific, non-negotiable set of federal obligations toward every tenant. He met none of them, not once, across seven years of leasing.

• The four properties are: 359 Maria Avenue (multi-family), 855 Hague Avenue (multi-family), 523 Laurel Avenue (multi-family), and 880 York Avenue (single-family). All are located in St. Paul, Minnesota, and all are confirmed to have been constructed before 1978.
• The EPA issued an administrative subpoena to Meints on December 4, 2023, demanding copies of all rental agreements and lead-based paint disclosure documentation covering January 1, 2019 through December 4, 2023. Meints responded on January 31, 2024.
• The documents Meints provided confirmed that across 23 lease transactions, he had failed to include a lead warning statement, a disclosure of known lead hazards, a list of available lead inspection records, a tenant receipt acknowledgment, or the required signatures and dates. Every single one of those five disclosure elements was missing from every single lease.
• The lease violations span from as early as August 2, 2016 (359 Maria Avenue, Apt. 1) through April 19, 2023 (855 Hague Avenue, Apt. 1). That is a documented pattern stretching nearly seven years.
• Of the 23 leases, at least eight were never signed at all, or were signed by only one party. Several have no date recorded. Three are described as having a “lease start date” but no signatures from either party.
• The maximum permissible civil penalty under the Toxic Substances Control Act for each violation occurring after November 2, 2015 is $22,263. The EPA documented 115 violations. The theoretical maximum exposure was approximately $2,560,245.

What a Lead Warning Is Actually For

Before we count violations and compare penalty amounts, it helps to understand what those lead disclosure forms actually represent in a person’s life.

Lead is a neurotoxin. There is no safe level of lead exposure for children. When paint that contains lead chips, flakes, or turns to dust, it ends up on floors, windowsills, and door frames. It gets on hands. It gets into mouths. Children under six are the most vulnerable because their brains and nervous systems are still forming. What lead exposure does to a developing child’s brain is permanent. It cannot be undone by a doctor’s visit, a settlement check, or a federal consent order filed in January 2026.

The federal disclosure law that Dennis Meints violated 115 times was not invented by bureaucrats looking for paperwork to generate. It was written in direct response to decades of evidence showing that low-income renters, and especially renters in older urban housing stock, were being poisoned in their homes without ever knowing the danger existed. The law’s entire logic is that a tenant who knows their apartment was built before 1978 and contains known or suspected lead hazards can make a real decision: ask for remediation, negotiate conditions, choose a different unit, keep their toddler away from the windowsills. That decision was taken away from every single person who signed a lease with Dennis Meints.

Look at 855 Hague Avenue. Eighteen separate leasing transactions at one building. Tenants cycling through. Families moving in. Some of those leases were never signed by the landlord at all. Some were never signed by anyone. At least one lease has a tenant signature on one copy and a landlord signature on a completely different copy, so no single document was ever agreed upon by both parties in the same room or even on the same page. These are not administrative oversights. This is a building where people were handed keys without paperwork, without warnings, and without the federal pamphlet that would have explained what lead paint can do to the children living inside those walls.

The families who moved into these buildings were not told to look out for peeling paint. They were not told to wet-mop instead of dry-sweep. They were not told to wash their children’s hands before meals. These are real behaviors that real people change when they know lead is present. They were denied the information that would have triggered those behaviors. That is the cost that does not appear in the $1,000 line of the Final Order.

“A tenant who knows the danger can protect their child. Dennis Meints’s tenants were never given that chance, across seven years and four buildings.”

The EPA’s own settlement document acknowledges that the penalty was reduced to $1,000 based on Meints’s “limited ability to pay.” That may be the legally required calculation. It does not change the arithmetic on the other side of the ledger, the one that tallies the number of tenants who slept in those units for months or years without ever being told what was in the walls around them.

Straight From the Document: What the EPA Put in Writing

The following are direct verbatim quotes from EPA Consent Agreement and Final Order, Docket No. TSCA-05-2026-0014, filed January 7, 2026. These are not paraphrases.

“Respondent failed to include, before the lessee was obligated under a contract to lease the housing, either within the contract or as an attachment to the contract to lease target housing, a Lead Warning Statement as set out in 40 C.F.R. § 745.113(b)(1) in 23 lease contracts.” CAFO §28, Counts 1-23

• This confirms that zero of the 23 leases contained the required lead warning statement. The warning is not optional language. It is a federally mandated statement that must appear before the tenant is legally bound. Not one lease included it.
• This count alone constitutes 23 separate federal violations under 40 C.F.R. § 745.113(b)(1), 15 U.S.C. § 2689, and 42 U.S.C. § 4852d(b)(5).

“Respondent failed to include, before the lessee was obligated under a contract to lease the housing, either within the contract or as an attachment to the contract to lease target housing, a statement by the lessor disclosing either the presence of any known lead-based paint and/or lead-based paint hazards in the target housing or a lack of knowledge of such presence, in 23 lease contracts.” CAFO §31, Counts 24-46

• This is the core of the disclosure requirement: Meints was legally required to either say “I know there is lead here” or “I have no knowledge of lead here.” He did neither, for every lease. Tenants were given no information at all, not even a statement of ignorance.
• The law does not require a landlord to perform lead testing. It requires them to share whatever they do or do not know. Meints chose silence over both options, 23 times.

“Respondent failed to include, either within the contract or as an attachment to the contract to lease target housing, a list of any records or reports available to the lessor regarding lead-based paint and/or lead-based paint hazards in the housing that have been provided to the lessee or a statement that no such records are available, in 23 lease contracts.” CAFO §34, Counts 47-69

• If any inspection records, renovation records, or prior hazard assessments existed for these properties, tenants were legally entitled to see them or to be told explicitly that none existed. No such disclosure was made in any lease.
• The document does not state that no records existed. It states that no disclosure was made. These are different facts with different implications for what tenants were denied.

“EPA has determined that an appropriate civil penalty to settle this action is $1,000. EPA conducted an analysis of Respondent’s financial information and determined Respondent has a limited ability to pay.” CAFO §44-45

• The statutory maximum per violation is $22,263. With 115 documented violations, the uncapped maximum exposure was approximately $2,560,245. The settled amount is $1,000. The reduction factor is roughly 2,560 to 1.
• The TSCA does permit the EPA to consider a violator’s ability to pay when setting a penalty. This provision exists to prevent bankrupting small-scale landlords. It does not require the EPA to reduce penalties to a symbolic amount. The decision to settle at $1,000 was a discretionary choice, not a legal inevitability.
• Meints neither admits nor denies any of the 115 violations. His waiver of appeal rights means no court will ever rule on whether the violations actually harmed anyone. The legal record contains 115 documented counts and a $1,000 check. That is the full extent of his accountability under federal law.

“In accordance with 40 C.F.R. § 22.18(c), completion of the terms of this CAFO resolves only Respondent’s liability for federal civil penalties for the violations specifically alleged in this CAFO.” CAFO §57

• This clause is critical. Paying $1,000 ends Meints’s federal civil penalty liability for these specific violations. It does not prevent state enforcement actions, does not preclude civil suits by individual tenants who suffered harm, and does not bar future federal action if new violations are discovered.
• Any tenant who believes they or their children were harmed by lead exposure in one of these units still has potential legal recourse outside of this EPA action. The CAFO explicitly does not close that door.

Seven Years, No Warning, One $1,000 Fine

The documented lease violations run from August 2016 through April 2023. The EPA did not issue its subpoena until December 2023. Here is how the timeline unfolded.

What the Law Required vs. What Tenants Actually Got

Federal disclosure law is specific and unambiguous. Here is what each tenant was legally entitled to before signing a lease, compared to what the EPA’s enforcement record shows they actually received.

The Damage Beyond the Docket Number

Public Health

Lead poisoning is a pediatric public health crisis with outcomes that compound across a lifetime. The disclosure failures documented here are not technical paperwork violations. They are the mechanism by which families were denied the ability to protect their children.

• The Centers for Disease Control and Prevention has established that there is no safe blood lead level in children. Even low-level exposure is associated with reduced IQ, attention disorders, impaired hearing, and delayed development. These effects are irreversible.
• Pre-1978 housing is the single largest source of childhood lead poisoning in the United States. All four of Meints’s properties fall into this category. The lead paint risk is the entire reason the 1992 disclosure law exists.
• Children under six are at peak risk because of hand-to-mouth behavior, increased time spent on floors, and faster neurological development. Families with young children who moved into these units had no way to assess whether they should take precautions, because they were never told precautions were warranted.
• Dust from deteriorating lead paint is invisible and odorless. Tenants who were never given the Lead Hazard Information Pamphlet would not have known that dry-sweeping, certain renovation activities, or opening and closing old windows can disturb lead dust. The pamphlet exists precisely to teach tenants these behaviors. None of Meints’s tenants received it.
• St. Paul, Minnesota has documented elevated childhood blood lead levels in specific zip codes, particularly in areas with dense pre-1978 housing stock. The neighborhoods where these four properties are located, including 55106 (Maria Ave), 55104 (Hague Ave), and 55102 (Laurel Ave), fall within the city’s historically higher-risk corridors.

“The pamphlet that Meints never handed over to a single tenant exists because it teaches people how to keep their children from being poisoned in their own homes. That pamphlet was never given to anyone.”

Economic Inequality

The structural conditions that made this violation pattern possible, and the penalty structure that resolved it for $1,000, reflect a system where low-income renters absorb risk that wealthier homeowners do not face.

• Pre-1978 rental housing is disproportionately occupied by low-income renters who have fewer housing choices. The populations most concentrated in older rental housing stock are the ones least likely to have the resources to test for lead themselves or to absorb the medical and developmental costs if exposure occurs.
• The ability-to-pay reduction that brought Meints’s penalty from a potential $2.56 million to $1,000 is a legal provision designed to prevent penalty structures from bankrupting small landlords. Its application here results in a cost-per-violation of approximately $8.70. For context, a standard pediatric blood lead level test at a clinic costs more than that.
• Tenants who signed leases without the required disclosures had no documented baseline of the landlord’s stated knowledge. In the event of a lead-exposure claim, the absence of any disclosure paperwork makes it harder for a tenant to establish that the landlord had or should have had knowledge of the hazard, since the legal record now shows only that he failed to disclose, not what he actually knew.
• The EPA’s enforcement action resolves only federal civil penalty liability. It provides no remediation of the properties, no compensation to tenants, no testing of children who lived in the units, and no medical monitoring program. The $1,000 goes to the U.S. Treasury, not to any affected family.
• Eight or more of the 23 leases were either unsigned or partially signed. Tenants occupying units without a fully executed lease have diminished legal standing in landlord-tenant disputes, including disputes over repairs that could reduce lead hazards, such as repainting, window replacement, or floor refinishing.

What $1,000 Means in the Real World

What Now: Who Is Accountable and What You Can Do

The CAFO names the individuals who authorized and signed this settlement. The regulatory bodies that enforce lead disclosure law still have jurisdiction over Meints for any future violations. And tenants have options that the EPA’s administrative settlement did not close.

Named Officials on This Enforcement Action

• Dennis Meints — Respondent. Sole proprietor, St. Paul, Minnesota. Owner and lessor of all four properties. Signed the CAFO on December 30, 2025.
• Carolyn Persoon — Acting Division Director, Enforcement and Compliance Assurance Division, EPA Region 5. Signed the CAFO on behalf of the EPA on January 5, 2026.
• Ann L. Coyle — Regional Judicial Officer, EPA Region 5. Issued the Final Order on January 6, 2026.
• Michael Todd — Enforcement and Compliance Assurance Division, EPA Region 5. Listed as the EPA contact for proof of payment submission.
• Mary McAuliffe — Office of Regional Counsel, EPA Region 5. Listed as EPA legal counsel contact.

Regulatory Watchlist: Who Oversees This

• U.S. EPA Region 5 (Chicago) — Primary enforcer of TSCA and the Lead Disclosure Rule for Minnesota, Illinois, Indiana, Michigan, Ohio, and Wisconsin. The office that brought this case. Contact: r5lecab@epa.gov.
• EPA Office of Enforcement and Compliance Assurance (OECA) — National oversight body for EPA enforcement actions. Tracks compliance history. This CAFO is now part of Meints’s permanent enforcement record.
• Minnesota Department of Health (MDH) — State agency responsible for childhood lead poisoning prevention. Operates a blood lead surveillance program and can investigate properties with documented lead hazards.
• Minnesota Department of Labor and Industry — Has jurisdiction over lead-safe work practices in renovation, repair, and painting under state and federal RRP Rule (Renovation, Repair, and Painting Rule).
• City of St. Paul Department of Safety and Inspections — Local code enforcement. Can inspect rental properties for housing code violations including lead hazard conditions. Tenants can file complaints directly.
• HUD Office of Fair Housing and Equal Opportunity — Lead disclosure failures in housing with federal funding connections may also fall under HUD jurisdiction. Relevant if any of the units were Section 8 or HCV voucher units.

What Tenants and Community Members Can Do Right Now

• If you rented from Dennis Meints: Request a copy of your lease and compare it against the five federally required disclosures. If any are missing, contact the EPA Region 5 office and the Minnesota Department of Health. The CAFO’s resolution of federal civil penalties does not prevent you from filing a separate civil lawsuit for damages if you or your child suffered harm from lead exposure.
• Get your child tested: If you lived at 359 Maria Ave, 855 Hague Ave, 523 Laurel Ave, or 880 York Ave in St. Paul in a unit built before 1978, request a blood lead level test from your child’s pediatrician. Testing is often covered by Medicaid and CHIP at ages one and two with no out-of-pocket cost.
• File a property complaint: St. Paul’s Department of Safety and Inspections accepts tenant complaints about rental property conditions including suspected lead paint hazards. You do not need to currently live in the unit to flag a concern about a building.
• Know your disclosure rights: Before signing any lease in a pre-1978 building, demand the lead warning statement, a hazard disclosure, and the EPA pamphlet “Protect Your Family From Lead in Your Home.” If a landlord refuses or claims they do not have it, that is itself a violation. Report it to EPA Region 5.
• Support local tenant unions: Organizations like the HOME Line in Minnesota (homelinemn.org) provide free legal assistance and advocacy for renters facing unsafe housing conditions. Collective tenant organizing is the fastest path to systemic enforcement pressure that individual complaints rarely generate.
• Demand stronger EPA penalties: The ability-to-pay provision that produced a $1,000 settlement for 115 violations is a regulatory discretionary choice, not an immovable legal floor. Public pressure on EPA Region 5 and on Congress to establish minimum per-violation floors for lead disclosure enforcement is a concrete legislative target.