Your Landlord Knew About the Lead and Said Nothing
TL;DR
- Pappas Investment Properties, LLLP and its owners, Dimitri Papadimitropoulos and Konstantino Papadimitropoulos, were caught by the EPA failing to give tenants the legally required lead poisoning warning materials at two Commerce City, Colorado rental properties.
- Federal law requires landlords of pre-1978 housing to hand tenants an EPA-approved pamphlet titled “Protect Your Family From Lead in Your Home” and to obtain written confirmation that tenants received it. Pappas did neither at two documented addresses.
- The two confirmed violations occurred at 4821 E 70th Avenue (lease signed January 1, 2023) and 7001 Poplar Street (lease signed February 6, 2024), both in Commerce City, Colorado 80022.
- The penalty assessed was $6,640 total, despite each violation carrying a maximum statutory penalty of $49,722. That means Pappas paid roughly 6.7 cents on the dollar for each infraction.
- The EPA’s first inspection attempt on May 18, 2023 failed because the on-site property manager did not have the required records. Pappas then submitted documents over nearly two years, from July 26, 2023, to April 11, 2025, before this consent agreement was finalized.
- Respondents neither admitted nor denied the factual allegations. They waived all rights to appeal, challenge, or seek judicial review of any term in this agreement.
- EPA reserves the right to pursue criminal liability and additional violations not covered by this settlement. This agreement resolves only the two specific lease violations documented here.
The statutory maximum penalty for these two violations was $99,444. Pappas paid $6,640. The math on what a child’s lead exposure is worth to this company is in “The Cost of a Life” section.
The Non-Financial Ledger: What the Fine Doesn’t Cover
Imagine you sign a lease. You have no idea the building went up before 1978. You have no idea that lead paint might be flaking off the trim in the room where your kid sleeps, or hiding in the dust that settles on the floor where a toddler puts their hands in their mouth a hundred times a day. Nobody told you. Nobody handed you a pamphlet. Nobody made you sign a form confirming you understood the risk. You moved in because you needed a home, and you trusted that someone whose job it is to know these things would have told you if there was something you needed to know.
That trust was misplaced in Commerce City, Colorado.
Lead poisoning does not announce itself. It does not cause a rash or a fever that sends you to the emergency room. It is quiet and cumulative. In young children, it attacks the developing brain. It lowers IQ permanently. It shortens attention span. It makes it harder to regulate emotion and behavior. Children who are lead-poisoned at a young age are statistically more likely to struggle in school, more likely to face disciplinary action, and more likely to cycle into systems that have no interest in understanding why they are struggling. The harm compounds across a lifetime.
The law that Pappas Investment Properties broke is not obscure or technical fine print. The Residential Lead-Based Paint Hazard Reduction Act of 1992 was passed specifically because Congress recognized that landlords of older housing hold information that tenants need to make decisions about their own families’ safety. The pamphlet that should have been handed to tenants at 4821 E 70th Avenue and 7001 Poplar Street is called “Protect Your Family From Lead in Your Home.” The title is not subtle. The obligation is not complicated.
Pappas did not hand over those pamphlets. The company did not obtain written confirmation that tenants received the lead hazard information they were legally entitled to. The people who signed those leases walked into their new homes without knowing what they were walking into. Whatever happened to them or their children in those homes after those lease dates is a chapter of this story that the EPA enforcement file does not contain, because nobody went back to ask.
“Lead exposure is especially harmful to young children and pregnant women.” This is the warning Pappas was legally required to deliver. They chose not to.
Dimitri Papadimitropoulos and Konstantino Papadimitropoulos run a limited liability limited partnership. That legal structure exists specifically to protect personal assets from business liability. The $6,640 penalty will not change how they operate their business. It will not restore a child’s cognitive development. It will not compensate a pregnant woman who lived in one of those units without being told her home might contain a federally recognized developmental toxin. No dollar amount in this consent agreement accounts for any of that, because the EPA’s enforcement action addresses only the paperwork violation, not its consequences.
Legal Receipts: What the Document Actually Says
The following are verbatim quotes from the EPA Consent Agreement, Docket No. TSCA-08-2026-0001, filed December 30, 2025. These are the official findings of the United States Environmental Protection Agency.
“For each of the leases referenced in paragraph 23 and 24, above, Respondents failed to obtain a statement by the lessees affirming receipt of the lead hazard information pamphlet required under 15 U.S.C. § 2686, as required by 40 C.F.R. § 745.113(b)(4).”
Consent Agreement, Paragraph 26 — EPA Region 8, Docket No. TSCA-08-2026-0001
- This is the core finding. At both documented addresses, Pappas did not obtain the written tenant acknowledgment required by federal law. This is not a disputed allegation; it is documented by records Pappas itself submitted.
- The phrase “affirming receipt” is key. The law does not just require that the pamphlet exist somewhere. It requires that tenants sign off confirming they received it. That confirmation is the only accountability mechanism available to tenants. Pappas eliminated that mechanism at both properties.
“The May 18, 2023, inspection could not be completed because the property manager on site that day did not have the records necessary for the inspection.”
Consent Agreement, Paragraph 20 — EPA Region 8, Docket No. TSCA-08-2026-0001
- The EPA showed up to inspect compliance with lead disclosure rules in May 2023. The on-site property manager had none of the required records on hand. This is the first documented signal that record-keeping at Pappas properties was not a priority.
- Federal regulations require lessors of target housing to maintain records. The inability to produce them during an EPA inspection is itself an indicator of systemic non-compliance, not an isolated administrative hiccup.
“Housing built before 1978 may contain lead-based paint. Lead from paint, paint chips, and dust can pose health hazards if not managed properly. Lead exposure is especially harmful to young children and pregnant women. Before renting pre-1978 housing, lessors must disclose the presence of known lead-based paint and/or lead-based paint hazards in the dwelling. Lessees must also receive a federally approved pamphlet on lead poisoning prevention.”
Required Lead Warning Statement, 40 C.F.R. § 745.113(b)(1), quoted in Consent Agreement Paragraph 11
- This is the exact language that must appear in every lease for pre-1978 housing under federal law. It is mandatory disclosure text, not optional boilerplate.
- The consent agreement documents that Pappas failed to obtain tenant acknowledgment of this warning at both addresses. The warning that “lead exposure is especially harmful to young children and pregnant women” was not confirmed as received by the people most at risk.
“By signing this Consent Agreement, Respondents: (a) acknowledges this Agreement constitutes an enforcement action for purposes of considering Respondents’ compliance history in any subsequent enforcement action; (b) admits the jurisdictional allegations made herein; (c) neither admits nor denies the factual allegations contained herein; and (d) consents to the assessment of the penalty specified in this Consent Agreement.”
Consent Agreement, Paragraph 30 — EPA Region 8, Docket No. TSCA-08-2026-0001
- “Neither admits nor denies” is standard legal language in settlements. Pappas did not go before a judge. They negotiated a payment and signed off. The factual record of what they did or did not do at these properties was never tested in any proceeding.
- The agreement does create a compliance history record. If Pappas is caught violating lead disclosure rules again, this consent agreement will be used against them in determining any future penalty. That is the primary deterrent mechanism built into this settlement.
“EPA may assess a civil penalty of up to $49,722 for each violation.” Pappas paid $3,320 per violation. The legal ceiling was $49,722 per violation.
Societal Impact: Who Gets Hurt When Landlords Skip the Paperwork
The violations documented in this case are not administrative technicalities. They are the structural conditions through which a preventable neurotoxin reaches children and pregnant women without their knowledge.
Public Health
- Lead poisoning in children causes permanent, irreversible neurological damage. There is no safe level of lead exposure, according to the Centers for Disease Control. The absence of a pamphlet and a signed acknowledgment means tenants at Pappas properties had no documented opportunity to make informed decisions about reducing their families’ lead exposure risk.
- The EPA’s required pamphlet, “Protect Your Family From Lead in Your Home,” contains actionable guidance: how to identify deteriorating paint, how to clean up lead dust, when to seek blood lead level testing for children. Tenants who never received it were denied that protective information during the exact period covered by their leases.
- Commerce City, Colorado is a working-class community with a significant Latino population. Housing discrimination and environmental burden historically concentrate in communities like Commerce City. Enforcement failures in these neighborhoods compound existing health disparities that already make residents more vulnerable to lead exposure.
- The second lease violation occurred in February 2024, more than eight months after the EPA’s initial inspection visit. Pappas was already under scrutiny for its lead disclosure practices when it signed a second non-compliant lease at 7001 Poplar Street. The pattern continued through active federal investigation.
Economic Inequality
- Renters in pre-1978 housing are disproportionately lower-income. They rent older housing because it is cheaper. That is also the housing most likely to contain lead paint. The federal disclosure law exists precisely because market dynamics already disadvantage these tenants; removing the disclosure requirement from the transaction strips them of the one legal protection designed to compensate for that imbalance.
- Lead-poisoned children have measurably lower lifetime earnings due to cognitive impairment, reduced educational attainment, and higher rates of involvement with the justice system. The economic literature on this is extensive. When landlords skip lead disclosures, they are offloading a long-term financial burden onto the families least equipped to absorb it.
- The maximum statutory fine of $49,722 per violation exists because Congress determined that a meaningful financial penalty was necessary to give landlords a genuine incentive to comply. The $3,320-per-violation settlement Pappas received is less than 7% of that maximum. For a property investment company, this settlement is a cost of doing business, not a deterrent.
- Respondents’ attorneys were from Greenberg Traurig, one of the largest and most expensive law firms in the United States. Tenants at 4821 E 70th Avenue and 7001 Poplar Street had no legal representation in this proceeding. They were not parties to the settlement. They received nothing from the $6,640 penalty payment.
The Cost of a Life: Running the Numbers
To translate that number into human terms: the National Institutes of Health and peer-reviewed economic research consistently estimate the lifetime economic cost of childhood lead poisoning at between $50,000 and $500,000 per affected child, accounting for lost wages, increased healthcare utilization, and social system costs. The $3,320 Pappas paid per violation does not cover the annual cost of a single pediatric blood lead level screening program for one family, let alone the downstream consequences if a child in one of those units was actually exposed.
- The EPA “considered the nature, circumstances, extent and gravity of the violations” as well as “the ability to pay” and “the effect of the proposed penalty on the ability to continue to do business.” The ability to continue to do business was weighted as a factor in reducing this penalty below the statutory maximum.
- The tenants at 4821 E 70th Avenue and 7001 Poplar Street were not given a comparable consideration. Their ability to continue living in their homes without knowledge of lead risk was not a factor that reduced anything for them.
What Now: How to Push Back
This consent agreement is a public document. The people named in it run a property investment company in Colorado and have a compliance history that the EPA will use in any future enforcement action. Here is what comes next and who to contact.
Named Respondents
- Pappas Investment Properties, LLLP: A limited liability limited partnership organized and doing business in Colorado. This is the entity directly held accountable in this consent agreement.
- Dimitri Papadimitropoulos: Named individually as a Respondent. Signed the January 1, 2023 lease at 4821 E 70th Avenue that is a documented violation.
- Konstantino Papadimitropoulos: Named individually as a Respondent. Also signed the January 1, 2023 lease at 4821 E 70th Avenue.
- The consent agreement binds Respondents’ “officers, directors, employees, agents, successors and assigns.” Any transfer of assets or change in ownership does not eliminate their obligations under this agreement.
Regulatory Watchlist
- U.S. EPA Region 8: The body that filed and resolved this enforcement action. Region 8 covers Colorado. They can be contacted regarding lead disclosure non-compliance at any property in the state. Compliance Officer on this case: Kristin Jendrek (Jendrek.kristin@epa.gov).
- U.S. EPA Office of Enforcement and Compliance Assurance: The national body that oversees TSCA Section 409 enforcement. Report suspected violations at: epa.gov/enforcement/report-an-environmental-violation.
- Colorado Department of Public Health and Environment (CDPHE): State-level environmental and public health regulator. Colorado may have additional state-level lead disclosure and inspection requirements beyond the federal floor.
- U.S. Department of Housing and Urban Development (HUD): HUD administers the lead-based paint disclosure program alongside EPA and can receive complaints about pre-1978 rental housing violations.
- U.S. Department of Justice: The consent agreement explicitly reserves EPA’s right to refer non-payment or breach of the agreement to the DOJ for civil action.
For Tenants and Organizers in Commerce City
- If you are renting a home built before 1978 anywhere in Colorado and you did not receive an EPA lead hazard pamphlet and were not asked to sign a receipt for it, your landlord may be in violation of federal law. Document the gap in writing and report it to EPA Region 8.
- Request a blood lead level test for any child under six who lives or has lived in pre-1978 housing where disclosure was not provided. Colorado Medicaid covers this test. Most private insurance is required to cover it for children in at-risk age groups.
- Connect with local tenant rights organizations in the Denver metro and Commerce City area. Mutual aid networks that work on housing justice can help document patterns of non-compliance across multiple properties and build the record needed for stronger enforcement or class actions.
- Share this EPA docket number: TSCA-08-2026-0001. It is a public record. Print it. Post it. It belongs to the community, not to the lawyers.
- Demand that your city council and Colorado state representatives expand tenant protections beyond the federal floor. The federal law sets a minimum. States and municipalities can require more: mandatory lead inspections before occupancy, stronger penalties, tenant access to the enforcement record.
The source document for this investigation is attached below.
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