The warning system EPA says broke down

When John Stewart Company entered six rental agreements for older California housing, EPA says the contracts left out every major lead-disclosure item identified in the agency’s order. The missing material allegedly included the federal Lead Warning Statement and the landlord’s statement about whether it knew of lead-based paint or related hazards.

The allegations extended beyond those six agreements. EPA said every one of the 11 leases listed in the order lacked the signatures and dates required to certify the accuracy of the landlord’s and renter’s statements.

The rules apply to what federal regulations call “target housing,” generally housing constructed before 1978, subject to specified exceptions. The order identifies John Stewart Company as the lessor and the 11 properties as target housing.

The required paperwork is supposed to put several facts into the lease record before or when the agreement is made:

1. Lead warning

   A prescribed warning statement attached to or included in the lease.

   Allegedly missing in 6

2. Landlord statement

   Known lead hazards disclosed, or a statement that the landlord has no knowledge.

   Allegedly missing in 6

3. Records list

   Available reports provided to the renter, or a statement that none are available.

   Allegedly missing in 6

4. Renter acknowledgment

   Confirmation of receiving the disclosures and required lead-hazard pamphlet.

   Allegedly missing in 6

5. Certification

   Signatures and dates certifying the parties’ statements to the best of their knowledge.

   Allegedly missing in 11

EPA treated each failure to comply as a separate alleged violation. The count of 35 comes from four alleged omissions in each of six leases, plus the alleged certification failure in all 11: 24 plus 11.

The settlement is final, but the allegations were not admitted

The respondent “neither admits nor denies the specific factual allegations” in the order. EPA consent agreement and final order, paragraph 24

That distinction matters. A consent order can impose an enforceable penalty without converting every factual allegation into an admission. Here, John Stewart Company admitted EPA’s jurisdiction, agreed to the settlement conditions, waived its right to contest the allegations, and waived its right to appeal the final order.

The company also certified that it was fully in compliance with the federal lead-disclosure regulations when it executed the agreement. The source does not explain what operational changes produced that compliance.

Eleven leases across four California cities

The leases date from January 2023 through February 2025. Four were in San Jose, four in Stockton, two in Suisun City, and one in Richmond.

Counts are derived from the numbered leases and allegations in paragraphs 17 through 22 of the order.

The geographic spread shows that the case was not tied to one building. Still, the supplied order does not say how EPA selected the 11 leases, whether they represented a broader portfolio review, or whether other leases were examined and found compliant.

What the paperwork gap means, and what it does not prove

Lead-disclosure rules create a renter-facing record. A lease should state whether the landlord knows of lead-based paint or hazards, identify available reports, carry the required warning, and document the renter’s receipt of information.

According to EPA, six contracts did not contain those statements and acknowledgments. That means the contracts themselves allegedly failed to provide the required information trail at the point of leasing.

• The contracts allegedly did not tell renters whether the company knew of lead-based paint or hazards.
• They allegedly did not list available lead-related records or state that no such records existed.
• They allegedly lacked renters’ written acknowledgment of receiving the disclosures and federal pamphlet.
• All 11 allegedly lacked the signatures and dates that certify the parties’ statements.

The order is narrower than a finding of exposure or injury. It does not say that any unit contained lead-based paint, that any renter failed to receive information through another channel, that children lived in the units, or that anyone suffered medical or financial harm. Those questions remain outside the supplied record.

A $31,567 penalty and a certification of compliance

The regulations cited in the order allowed a penalty of up to $22,263 for each qualifying violation. The parties instead agreed to a total civil administrative penalty of $31,567 to settle the specifically alleged violations.

• The penalty was due within 30 days of the order’s effective date.
• The company may not claim the payment as a federal, state, or local tax deduction.
• A late payment can trigger a stipulated penalty of $500 per day, plus other collection measures and charges described in the order.
• John Stewart Company certified that it was then fully compliant with the applicable disclosure regulations.
• The settlement resolves federal civil penalties only for the facts and violations specifically alleged in the order.

The document states that it becomes effective when the final order is filed. Its cover bears a September 21, 2026 filing stamp from the EPA Region IX hearing clerk. The supplied record does not confirm whether the company later paid the penalty.

The case shows why disclosure rules are more than a stack of forms. They are the required channel for placing hazard knowledge, available records, and renter acknowledgment into a verifiable contract. EPA’s order says that channel failed repeatedly. What it does not reveal is whether the missing record concealed an actual hazard or produced a measurable injury.