A Landlord Left Tenants In The Dark About Lead Paint. The EPA Fined Him $100.

The Non-Financial Ledger

Families rented three separate homes in Moline built before 1978, when lead paint was still legal and common, without ever being told whether the walls around their children contained a known hazard. That is not missing paperwork. That is a landlord deciding a tenant’s right to know did not matter enough to fill out a form.

According to records the company was forced to hand over under federal subpoena, none of the three leases included a lead warning statement, a hazard disclosure, a list of any existing lead reports, or signatures confirming any of it happened. After leasing to one of these tenants without those disclosures, the company then moved to evict them.

Only for the third property did EPA document a tenant who never received the EPA’s own pamphlet, “Protect Your Family From Lead in Your Home,” before they were legally bound to move in. That family’s situation surfaced only because the tenant told the government directly.

Legal Receipts

“neither admits nor denies the allegations stated in Section D of this CAFO”

• This is standard language that lets a company pay a penalty without ever formally confessing to breaking the law.
• The public record contains an accusation but no admission, even though the company waived its right to contest the underlying facts.
• No future regulator can point to this case as documented proof of wrongdoing, despite the company paying a penalty tied to 16 specific counts.

“Respondent failed to provide a response to Complainant’s Request for Information.”

• EPA’s first attempt to check on lead paint compliance was simply ignored.
• That silence is what forced EPA’s next move: a federal administrative subpoena.
• Ignoring a regulator’s request added months to the case before any accountability began.

“Respondent has a limited ability to pay.”

• This is the government’s own stated justification for reducing the penalty to a token amount.
• It confirms EPA reviewed the company’s finances directly, rather than taking the company’s word for it.
• No specific financial figures were made public, so the public cannot verify what “limited ability to pay” means in dollars.

“EPA has determined that an appropriate civil penalty to settle this action is $100.”

• One hundred dollars covers 16 separate documented violations across three properties.
• That works out to $6.25 per violation, calculated by dividing the $100 penalty by the 16 counts in this record.
• The law allowed penalties of up to $22,263 for each individual violation of this exact type.

How Capitalism Exploits Delay: Time As A Corporate Weapon

EPA did not get straightforward cooperation once it started asking questions; it got silence, then had to force the issue.

• EPA requested compliance records on October 31, 2024; the company received that request on November 7, 2024, and never responded.
• Because of that silence, EPA escalated to a formal administrative subpoena on August 13, 2025, roughly nine months after the original request.
• The company did not turn over lease and eviction records until September 26, 2025, nearly a full year after EPA first asked.
• The formal settlement was not signed until June 13, 2026, more than five years after the earliest lease in this case began.

Societal Impact Mapping

Public Health

This case sits inside a rule built specifically to protect people from lead exposure in old housing.

• Federal law waives its lead disclosure requirement for elderly or disability housing unless a child under six lives there, which shows the rule was built around protecting young children from lead exposure.
• All three of Moline Automotive’s properties met the legal definition of “target housing” that this child-protection rule exists to cover.
• For at least one lease, the tenant never received the EPA’s own pamphlet explaining lead poisoning risk before they were legally bound to move in.
• Across three properties and multiple leases between 2020 and 2025, tenants had no documented, verified access to whatever lead hazard records, if any, existed for these buildings.

The Settlement Isn’t Justice

EPA had the legal authority to fine this company far more than it did, and did not require an admission of fault in exchange.

• With 16 documented violations and a per-violation cap of $22,263, the theoretical maximum penalty in this case was $356,208 (calculated from source figures: $22,263 × 16).
• EPA settled for $100, roughly 0.03 percent of that maximum (calculated from source figures: $100 ÷ $356,208).
• The settlement required no admission of wrongdoing: the company “neither admits nor denies” any of the 16 violations.
• The only thing tenants got in exchange was the company’s own certification that it is “currently in compliance,” with no independent verification method documented in this record.

This Is The System Working As Intended

Nothing in this case was a loophole. The rules produced exactly this outcome by design.

• The law set a penalty ceiling of $22,263 per violation specifically to deter this conduct, and EPA’s own settlement shows that ceiling can be reduced by more than 99.9 percent through an ability-to-pay finding with no public dollar figures attached.
• The company only produced records after being subpoenaed, and that non-cooperation did not prevent it from receiving the lowest realistic settlement outcome.
• The agreement counts as a formal “enforcement action” for any future violation, but the current record includes no independent monitoring requirement to confirm the company’s own certification of compliance.

What A Legitimate Fix Looks Like

This case shows a disclosure law with real teeth on paper losing its force the moment a small landlord’s finances become part of the enforcement math.

Regulatory Track

• Require independent verification, not just self-certification, before EPA closes a lead disclosure case, since this record relies solely on the company’s own statement that it is now compliant.
• Set a minimum enforceable disclosure penalty floor for landlords managing multiple rental properties (general industry standard), since a per-violation cap that can shrink to $6.25 per violation does not track with a company that stonewalled a records request for nine months.
• Mandate a follow-up compliance check within a fixed window at properties named in a lead disclosure enforcement case (general industry standard), since this record contains no such requirement.

Legislative Track

• Require that “limited ability to pay” findings under the Lead Act be published with the underlying financial figures, since this record cites the finding without showing the numbers behind it.
• Close the structural gap that allows an ability-to-pay reduction to apply once per case rather than per violation, since this deduction collapsed 16 separate violations into a single token penalty.

Corporate Governance Track

• Require landlord entities managing multiple pre-1978 rental properties to designate a single compliance-responsible officer for lead disclosure paperwork, since this case shows the identical disclosure failure repeated across three separate leases over five years.
• Require standardized, pre-approved lease riders containing all required disclosures, since every one of the 16 counts in this case traces back to the same missing paperwork.

What Now?

This case is closed, but the properties, the landlord, and the regulator are not.

• Watchlist: EPA Region 5, Enforcement and Compliance Assurance Division, which holds the enforcement file on Moline Automotive, Inc. and any future violations of this CAFO.
• Tenants in older Moline-area housing built before 1978 can request lead disclosure paperwork directly from any landlord before signing a lease, since the law requires it regardless of enforcement delays.
• Renters who never received a signed lead disclosure statement can report it to EPA Region 5 directly, the same way the tenant tip behind Count 16 in this case did.
• Local tenant groups can cite this public docket number, TSCA-05-2026-0029, as a documented example when pressing local officials for stronger lead-safe housing enforcement.