The Non-Financial Ledger: What a Lease Without a Warning Actually Costs

Imagine signing a rental agreement and moving your family into a home. You have no idea the walls were painted before 1978. You have no idea that lead-based paint was standard in residential construction for most of the twentieth century. You have no idea that when that paint chips, flakes, or turns to invisible dust, it can get into your child’s body and stay there, permanently altering how their brain develops. You have no idea because the person who handed you the lease and took your deposit did not tell you. Was legally required to tell you. And chose not to.

That is what happened to at least 15 households across Goshen, Elkhart, Cassopolis, Niles, and Edwardsburg between 2018 and 2022. The families who moved into Rogers’ properties signed leases for terms longer than 100 days each. That is months of exposure. Months of a child crawling on floors dusted with microscopic lead particles. Months of a toddler touching painted windowsills and putting hands in their mouth. Federal law exists specifically to prevent this. The Residential Lead-Based Paint Hazard Reduction Act was passed in 1992 because the government knew this was happening and knew landlords would not voluntarily warn tenants without a legal mandate.

The disclosure system is not complicated. It does not require a landlord to test their properties or pay for remediation. It requires a landlord to hand over a pamphlet, include a paragraph in the lease, and sign their name confirming they did it. That is the floor of their obligation. The minimum. And Ronnie Rogers did not meet it, not once, across fifteen separate transactions spanning four years and two states.

What the EPA settlement captures in legal language, what it reduces to numbered paragraphs and dollar figures, is the systematic stripping of a tenant’s right to make an informed choice about where they raise their children. No family is given back the months they spent unknowing. No child who may have been exposed gets a refund of IQ points or a reversal of neurological damage. The $10,000 Rogers ultimately paid does not flow to his tenants. It goes to the federal government. The people who actually lived in those homes receive nothing from this enforcement action beyond the cold comfort that someone, eventually, noticed.

Lead poisoning is permanent. There is no treatment that reverses it. In children under six, even low levels of exposure are linked to reduced attention span, lower academic performance, increased aggression, and lifelong earnings deficits. The CDC states there is no safe blood lead level in children. This was not a clerical oversight. This was four years of renting pre-1978 housing to families while systematically leaving out the one page of paper that was legally required to protect them.

Legal Receipts: What the Federal Order Actually Says

These are verbatim quotes from the EPA’s Consent Agreement and Final Order, Docket No. TSCA-05-2025-0008, filed April 10, 2025.

“Respondents failed to provide the lessee the EPA-approved lead hazard information pamphlet for the leases of Respondents’ properties at the 15 addresses listed in Paragraphs 19 and 20, above.”

EPA CAFO, Paragraph 25 — Counts 1-15

• This quote confirms Rogers never handed tenants the federally mandated “Protect Your Family From Lead in Your Home” pamphlet at any of the 15 properties. The pamphlet is free to download and takes seconds to print. Its absence represents a deliberate or grossly negligent omission repeated fifteen times.
• This single failure constitutes 15 separate federal violations on its own, before counting any of the other missing disclosures.

“Respondents failed to include a lead warning statement, either within the contract or as an attachment to the contract for the lease of Respondents’ properties at the 15 addresses listed in Paragraphs 19 and 20, above.”

EPA CAFO, Paragraph 28 — Counts 16-30

• A “lead warning statement” is a legally prescribed block of text that must appear in every lease for pre-1978 housing. It is not an optional addendum. Its omission from all 15 leases adds another 15 violations to the count.
• Tenants signing these leases had no written notice whatsoever that the federal government considers their housing a potential lead hazard environment.

“Respondents failed to include a statement 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.”

EPA CAFO, Paragraph 31 — Counts 31-45

• The law does not require a landlord to have tested for lead. It requires them to state either what they know, or that they do not know. Rogers did neither. Fifteen more violations.
• This is the disclosure that would have allowed tenants to ask follow-up questions, demand testing, or choose a different home. Its absence removed that choice entirely.

“EPA conducted an analysis of Respondents’ financial information and determined Respondents have a limited ability to pay. Consequently, in accordance with applicable law, EPA determined that the Assessed Penalty is an appropriate amount to settle this action.”

EPA CAFO, Paragraph 43 — Civil Penalty

• The maximum penalty per violation was $21,699. With 90 violations, Rogers’ theoretical maximum liability was $1,952,910. The EPA settled for $10,000, roughly 0.5% of the statutory maximum, citing his limited finances.
• The tenants whose children may have been exposed to lead during those lease terms received no financial consideration in this settlement. The penalty flows entirely to the federal government.

“Respondents failed to include a list of any records or reports available to the lessor regarding lead-based paint and/or lead-based paint hazards in the target housing that have been provided to the lessee or a statement that no such records are available.”

EPA CAFO, Paragraph 34 — Counts 46-60

• Even if Rogers had no inspection reports at all, he was legally required to say so. The law specifically accommodates the “I don’t know” answer. He did not use it. Fifteen more violations.
• The absence of this disclosure means tenants had no basis to know whether prior inspections had been conducted, whether hazards had been previously identified, or whether remediation had ever been attempted.

Ninety Violations: The Complete Breakdown

Six distinct categories of required disclosure were omitted from every one of the 15 leases. Each omission per lease is a separate federal violation. The chart below shows how 90 total violations accumulate from six categories of failure.

What Tenants Were Given vs. What the Law Required

Federal law under 40 C.F.R. Part 745 specifies exactly what a pre-1978 rental lease must contain. Compare the legal requirement to what Rogers actually provided his tenants.

Societal Impact Mapping

Public Health

Lead is a neurotoxin. The communities in Goshen, Elkhart, Cassopolis, Niles, and Edwardsburg that hosted Rogers’ rental properties absorbed risk they were never told existed.

• All 15 properties are classified as “target housing,” meaning they were built before 1978 when lead-based paint was standard in residential construction. The age of these structures means the risk of deteriorating lead paint is structural, not hypothetical.
• The CDC has established that there is no safe level of blood lead in children under six. Rogers’ properties hosted families with children who, per the terms of federal law, are the primary protected class the disclosure rule was designed to safeguard.
• Each lease covered a term greater than 100 days. That is a minimum of more than three months of continuous exposure for each household, during which tenants had no documented warning to avoid lead-paint risks such as renovation dust, deteriorating paint near windows and doors, or soil contamination near the foundation.
• Lead poisoning symptoms in children are often silent until developmental delays appear, sometimes years after exposure. The families in these 15 households may not know today whether their children were harmed.
• The disclosure rule was specifically designed to allow tenants to take protective action: keeping children away from peeling paint, requesting inspections before renovation work, or choosing alternative housing. Rogers’ omissions removed every one of those protective options from his tenants.

Economic Inequality

Lead disclosure violations are not evenly distributed across the rental market. They concentrate in working-class rental housing, where tenants have less bargaining power and fewer alternatives.

• The properties span low-income and working-class communities in rural and small-city Indiana and Michigan: Goshen, Elkhart, Cassopolis, Niles, and Edwardsburg. These are not luxury markets where tenants can easily walk away from a lease over missing paperwork.
• The EPA’s own determination that Rogers had a “limited ability to pay” confirms he operated in a low-margin segment of the rental market, where cost-cutting at the expense of tenant safety is most likely to occur and least likely to be independently audited.
• The $10,000 penalty Rogers paid is a fraction of the rental income generated by 15 properties over a four-year period. It functions as a cost of doing business, not a deterrent. Tenants bear the health consequences while the financial consequence to the landlord is minimal.
• Families who cannot afford owner-occupied housing in newer construction are forced into the pre-1978 rental stock that carries lead risk. Disclosure violations deny them the one protection the law provides in lieu of the financial ability to choose a safer home.
• Lead poisoning’s documented long-term economic effects include lower educational attainment and lifetime earnings. If any child in these 15 households was exposed, the economic harm to their family compounds over decades, vastly exceeding the $10,000 Rogers paid to resolve the federal case.

The “Cost of a Life” Metric

What Now?

The federal settlement is closed. Rogers paid $10,000, certified compliance, and waived his right to appeal. The tenants of all 15 properties remain entitled to pursue independent civil legal action if they can document harm. Here is what you can do with this information.

Who Signed the Settlement

• Ronnie R. Rogers, Sr. signed on behalf of himself individually and as Registered Agent of Ronnie R. Rogers Properties, LLC.
• Michael D. Harris, Director, Enforcement and Compliance Assurance Division, EPA Region 5, signed for the Complainant.
• Ann L. Coyle, Regional Judicial Officer, EPA Region 5, issued the Final Order on April 10, 2025.

Regulatory Watchlist

• EPA Region 5 (Chicago): The enforcing body in this case. They maintain a public docket for all TSCA enforcement actions. Monitor Docket No. TSCA-05-2025-0008 for compliance confirmation.
• EPA Office of Enforcement and Compliance Assurance (OECA): The national office that sets lead disclosure enforcement policy. Contact them if you believe Rogers is non-compliant after the settlement date.
• Indiana Department of Health (IDOH): Administers lead poisoning prevention programs for Indiana tenants. If you lived in a Rogers property in Goshen or Elkhart, you can request a blood lead level test through your county health department.
• Michigan Department of Health and Human Services (MDHHS): Administers lead programs for Michigan residents. Tenants from Cassopolis, Niles, or Edwardsburg Rogers properties can access testing and reporting resources through MDHHS.
• HUD Office of Lead Hazard Control and Healthy Homes: Funds local lead testing and remediation programs. If you are a current or former tenant of a pre-1978 rental home and were not given lead disclosures, HUD programs may cover testing costs.

Mutual Aid and Organizing

• If you rented from Rogers between 2018 and 2022: Contact a tenant rights attorney in Indiana or Michigan about a private civil action for failure to disclose. The CAFO’s factual findings, though not admitted by Rogers, are public record and document the omissions. You do not need to wait for the federal government to act on your behalf.
• Request your children’s blood lead level history: Contact your pediatrician or county health department. Indiana and Michigan both have childhood blood lead surveillance programs. Testing is the only way to know if exposure occurred.
• Report current violations in your rental: If you are renting a pre-1978 home right now and were not given a lead hazard pamphlet or a lead warning statement in your lease, file a complaint with EPA Region 5 at (800) 621-8431. This is a federal violation with penalties of up to $21,699 per offense.
• Connect with local tenant unions: Elkhart County, Cass County, and Berrien County have active housing advocacy groups. Organizing with neighbors is the most effective way to ensure landlords in your community follow disclosure law, because federal enforcement is reactive, not proactive.
• Push for local lead disclosure audits: Contact your city or county council representative and request that rental inspections include lead disclosure compliance review. Most local housing inspections do not currently verify federal disclosure requirements.