Corporate Accountability Project · EPA Enforcement Series · Lead Paint Violations
Lead Paint Disclosure Failure · Colorado
Pappas Investment Properties Withheld Mandatory Lead Warnings from Colorado Renters
A Colorado real estate partnership and its individual owners leased pre-1978 housing in Commerce City without providing federally required lead hazard disclosures, leaving tenants without the health warnings the law demands.
What Happened
Pappas Investment Properties, LLLP, along with its owners Dimitri and Konstantino Papadimitropoulos, rented out pre-1978 homes in Commerce City, Colorado without providing the federally required lead hazard information pamphlet or obtaining tenant acknowledgment that they received it. This was not a single error. The EPA visited the property in May 2023 and found the on-site manager did not even have the necessary compliance records. Two separate leases, signed in 2023 and 2024, both failed the same basic requirement: confirm that tenants were told about the lead poisoning risk in their home before they were legally bound to live there. Lead paint is the leading environmental cause of childhood lead poisoning in the United States. Every lease that skips this step is a lease that puts a family in the dark.
Renters have a federal right to lead hazard information. Landlords who skip it must face real consequences.
2
Leases Missing Required Lead Disclosures
2
Federal Violation Counts
3
Named Respondents (Entity + 2 Individuals)
$6,640
Civil Penalty Assessed
2023–24
Period of Documented Violations
$49,722
Maximum Penalty Per Violation Under TSCA
Allegations
Core Allegations
What Pappas Did · 6 Points
| 01 | Pappas Investment Properties, LLLP, along with named owners Dimitri Papadimitropoulos and Konstantino Papadimitropoulos, owned and operated pre-1978 residential properties in Commerce City, Colorado, making them legally subject to federal lead paint disclosure requirements. | high |
| 02 | On January 1, 2023, Dimitri and Konstantino Papadimitropoulos entered into a lease for the residential dwelling at 4821 E 70th Avenue, Commerce City, Colorado without obtaining tenant confirmation of receiving the required lead hazard pamphlet. | high |
| 03 | On February 6, 2024, Pappas Investment Properties, LLLP entered into a lease for 7001 Poplar Street, Commerce City, Colorado with the same failure: no tenant acknowledgment of lead hazard information receipt. | high |
| 04 | When EPA inspectors visited the apartment complex on May 18, 2023, the property manager on site did not have the compliance records necessary to complete the inspection. The EPA had to request documents through email instead. | med |
| 05 | Document submissions from Respondents stretched from July 26, 2023 to April 11, 2025, a nearly two-year period of back-and-forth with regulators to produce basic rental compliance records. | med |
| 06 | The EPA cited the violations as two counts under Section 409 of TSCA (15 U.S.C. § 2689), which prohibits failure or refusal to comply with federal lead hazard disclosure requirements for pre-1978 housing. | high |
Public Health Consequences
Who Was Put at Risk · 4 Points
| 01 | The dwellings leased by Pappas are “target housing” under federal law: pre-1978 residential buildings where children under six may live. The lead disclosure requirements were created specifically because these are the highest-risk homes for childhood lead poisoning. | high |
| 02 | The required pamphlet, “Protect Your Family From Lead in Your Home,” contains direct guidance on recognizing lead hazards, testing for lead, and protecting children and pregnant women. Tenants who never received it had no baseline knowledge of the risk. | high |
| 03 | Commerce City, Colorado has a significant population of working-class families and children in older housing stock. Lead disclosure failures in this community compound existing environmental health disparities in neighborhoods already burdened by industrial pollution. | med |
| 04 | Lead poisoning from deteriorating paint in rental housing is almost entirely preventable when landlords comply with federal disclosure and remediation rules. Pappas had both the legal obligation and the practical means to protect their tenants, and did not. | high |
Corporate Accountability Failures
Penalty vs. Maximum Exposure · 4 Points
| 01 | The maximum penalty under current TSCA regulations is $49,722 per violation. For two violations, the maximum would have been approximately $99,444. Pappas paid $6,640, representing a reduction of about 93 percent. | high |
| 02 | The EPA considered “the ability to pay, the effect of the proposed penalty on the ability to continue to do business, any history of prior violations, the degree of culpability, and such other matters as justice may require.” The result still permitted a significant reduction from maximum. | med |
| 03 | Respondents “neither admit nor deny” the factual allegations. The settlement is final and binding, but no court found wrongdoing, and Pappas faces no mandatory remediation, no tenant notification requirement, and no bar on future rental activity. | med |
| 04 | Individual owners Dimitri and Konstantino Papadimitropoulos are personally named respondents, which is significant. Both signed the consent agreement individually and as representatives of the partnership, making both personally liable for compliance going forward. | med |
Timeline of Events
Jan 1, 2023
Dimitri and Konstantino Papadimitropoulos sign a lease for 4821 E 70th Avenue, Commerce City without providing the required lead hazard pamphlet acknowledgment to tenants.
May 18, 2023
EPA Region 8 visits the apartment complex to conduct a compliance inspection. The on-site property manager lacks the necessary records. Inspection cannot be completed in person.
Jul 26, 2023
EPA requests leasing records by email. Respondents begin submitting documents via email. This back-and-forth continues for almost two years.
Feb 6, 2024
Pappas Investment Properties, LLLP signs a second non-compliant lease for 7001 Poplar Street, Commerce City, again without obtaining required lead disclosure acknowledgment from tenants.
Apr 11, 2025
Final email submission of leasing records to EPA. Document review reveals two separate violations of federal lead disclosure requirements across two properties and multiple parties.
Dec 15, 2025
Dimitri Papadimitropoulos signs the consent agreement on behalf of all respondents (individually and for Pappas Investment Properties, LLLP). David Cobb of EPA Region 8 signs for the government.
Dec 30, 2025
Consent Agreement and Final Order filed with the EPA Region 8 Hearing Clerk. Pappas Investment Properties, LLLP, Dimitri Papadimitropoulos, and Konstantino Papadimitropoulos agree to pay $6,640.
From the Federal Record
QUOTE 1
What the law requires of every landlord
Core Allegations
“Before the lessee is obligated under any contract to lease target housing that is not otherwise an exempt transaction, lessors shall complete the activities set forth in 40 C.F.R. § 745.107.”
💡 The timing matters: before the lease is signed. Not after. Not at move-in. Before. Pappas bound tenants to contracts without ever fulfilling this obligation.
QUOTE 2
The specific violation documented
Core Allegations
“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).”
💡 Two leases, two separate years, the same failure. This is not an accident. This is a systemic practice of skipping a federally required tenant protection in a business built on leasing housing to families.
QUOTE 3
What the required pamphlet contains
Public Health
“The lessor shall provide the lessee with an EPA-approved lead hazard information pamphlet. Such pamphlets include the EPA document entitled Protect Your Family From Lead in Your Home.”
💡 This pamphlet tells families how to spot lead hazards, what to do about them, and how to protect children and pregnant women. Pappas tenants never got it. They lived in that housing without it.
QUOTE 4
Penalty ceiling vs. penalty assessed
Accountability Failures
“EPA may assess a civil penalty of up to $49,722 for each violation of section 409. 15 U.S.C. § 2615(a)(1), 40 C.F.R. part 19, 90 Fed. Reg. 1375, 1377 (Jan. 8, 2025).”
💡 $49,722 per violation is the law’s stated deterrent. $6,640 total for two violations is 6.7 cents on the dollar compared to maximum. For an investment property firm, this barely registers as a cost of operations.
Commentary
What makes this case different from the Meints case in Minnesota?
▼
The Pappas case involves a formal business entity, an investment partnership, alongside individual owners, rather than a sole proprietor. That distinction matters: Pappas Investment Properties, LLLP is a for-profit real estate operation with multiple properties and a commercial real estate broker involved in its transactions. The violations are fewer in number (two versus 115), but the commercial nature of the operation means there is even less excuse for failing basic tenant protections. The $6,640 penalty, while larger than Meints’ $1,000, is still a fraction of the maximum and provides minimal deterrent to a business with ongoing property holdings.
Why does it matter that the property manager didn’t have records on inspection day?
▼
Federal lead disclosure compliance requires that records be maintained and accessible. When an EPA inspector arrives and the person managing the property cannot produce a single compliance document, that signals not just that paperwork was missing for two leases, but that there was no meaningful compliance system in place at all. If records were kept, an on-site manager would have them. The inability to produce records suggests the requirements were not being tracked, which raises questions about whether there are additional non-compliant leases that were not captured in the two documented here.
Is it significant that both individual owners are named personally?
▼
Yes. EPA enforcement naming both the entity and its individual owners is meaningful because it means the consent agreement binds both personally. Any future violations could be considered against both individuals in addition to the company. It also signals that the EPA does not accept the limited liability structure as a shield for the people who actually make compliance decisions. Landlords who operate investment properties through LLCs and LLLPs sometimes assume the entity absorbs all legal exposure. This case demonstrates that federal environmental regulators can and do pierce that structure when the conduct is directly attributable to individual owners.
What can I do to prevent this from happening again?
▼
Renters: when signing a lease for any building that looks pre-1978, specifically ask for the EPA lead hazard pamphlet “Protect Your Family From Lead in Your Home” and a written lead disclosure statement before you sign anything. If a landlord or property manager cannot provide both documents immediately, file a complaint with your regional EPA office at epa.gov/lead. Advocates: push local housing authorities to make lead disclosure documentation a required part of rental property registration and licensing, not just a federal obligation that goes unverified. Policymakers: the gap between the statutory maximum penalty and what is actually assessed undermines deterrence. Closing that gap with mandatory minimum penalties for lead disclosure violations would make non-compliance genuinely costly for investment landlords.
EPA i think the ftc might have done something here too lol TSCA-08-2026-0001 Pappas Investment Properties LLP CAFODownload
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