They Knew About the Lead. They Didn’t Tell the Tenants.

A Manhattan landlord collected rent from families in a pre-1978 lead-paint complex for years while federal inspectors found that 29 apartments had no record of tenants ever being warned about the poison inside their walls.

The Woodner Company, headquartered at 21 East 67th Street on Manhattan’s Upper East Side, managed Crestwood Lake Apartments in Yonkers while failing to provide legally required lead hazard disclosures to families living in 29 units of a building constructed before lead paint was banned in 1978.

This is the result the federal Lead Disclosure Rule was specifically designed to prevent. Congress passed that law after finding that lead poisoning from deteriorated paint dust was the most common cause of lead poisoning in American children in the entire country, and that pre-1978 housing stock contained more than three million tons of lead in the form of lead-based paint.

The Woodner Company managed the building. The families signed leases without the legally required warnings. The EPA found out in 2022. Woodner paid a penalty in 2025. Three years passed in between.

The Non-Financial Ledger: What Money Can’t Measure

The Warning That Never Came

Federal law does not ask landlords to remove lead paint. It does not require them to hire specialists or spend a single dollar on remediation. The Lead Disclosure Rule asks for something far simpler: tell the people who are about to live in your building what you already know. Give them the pamphlet. Get their signature. That’s it. The Woodner Company failed to do even that for families in 29 apartments.

Every one of those 29 households signed a lease agreement without a statement acknowledging they had received lead hazard information. Thirteen of those 29 households signed leases with no certification signature at all from either the landlord or the tenant confirming the accuracy of lead-related disclosures. These were not paperwork technicalities. The signature requirement exists specifically because the EPA uses it to verify whether a tenant was actually informed, not just whether a form existed somewhere in a filing cabinet.

The people who moved into those apartments had no way to know the legal protections designed for them had been skipped. They unpacked their lives, paid their rent, and went about trusting that a company operating out of Manhattan’s most expensive zip code had handled the basics. They were wrong to trust that.

Children Are the Target

The legal term for a building like Crestwood Lake Apartments is “target housing.” That word, target, describes the risk profile of the building, not a metaphor. Pre-1978 housing targets children under the age of six because that population is most vulnerable to the developmental consequences of lead exposure. The federal law Woodner violated exists entirely because of what lead does to young brains: it lowers IQ, causes behavioral problems, delays development, and produces harms that no medical intervention can fully reverse.

The disclosure form that was missing from those 29 lease files includes a mandatory Lead Warning Statement that reads: “Lead exposure is especially harmful to young children and pregnant women.” Families moving into apartments at Crestwood Lake deserved to read that sentence before they committed to a lease. They deserved the chance to ask questions, demand inspection reports, or walk away. The Woodner Company’s failure to include that statement removed their ability to make an informed decision entirely.

Across a 29-apartment footprint spanning addresses on Andover Road, Nassau Road, Shoreview Drive, Beaumont Circle, Cleveland Place, Roxbury Drive, and Crisfield Street, the pattern repeated itself. Twenty-nine times, tenants moved in without the information the law guaranteed them. The EPA inspected in May 2022 and obtained 30 lease files executed on or after May 1, 2020. Twenty-nine of them were deficient. That is not a clerical slip. That is a systemic practice.

Three Years of Living in the Dark

The EPA mailed its inspection report to Woodner on May 24, 2022. The consent agreement settling the violations was not finalized until September 29, 2025. That is more than three years between the EPA identifying the problem and a resolution being signed. The source document does not detail what remedial actions Woodner took with existing tenants during that window, or whether families who moved in during those years received proper disclosures. The compliance plan attached to the settlement was dated June 5, 2025, meaning the formal roadmap for future compliance was only written three years after the inspection.

What the source document does confirm is that Woodner neither admitted nor denied the EPA’s findings of fact. The company agreed to pay the penalty and comply going forward. No finding of formal liability was made. For the families in those 29 apartments, no official record exists that says what happened to them was wrong, only that it happened, and that it cost the company $59,500 (roughly what a minimum-wage worker in New York earns in two full years of labor) to make the federal government go away.

The Violation Map: 29 Apartments, 42 Failures

The EPA documented two separate types of disclosure failures across the 29 deficient lease files. Every single apartment lacked the tenant acknowledgment statement. A substantial subset also lacked the required certifying signatures from all parties. The chart below visualizes the full scope of documented violations by type.

The two violations documented are distinct federal requirements. The first, 40 C.F.R. § 745.113(b)(4), required a statement from the tenant confirming they actually received lead hazard information, including the EPA’s protective pamphlet. The second, 40 C.F.R. § 745.113(b)(6), required dated signatures from both the lessor and the lessee certifying the accuracy of all lead-related disclosures.

Every single one of the 29 deficient files failed the first requirement. Nearly half, 13 out of 29, also failed the second. The EPA is explicit: each failure constitutes an independent violation for which penalties may be individually assessed. Woodner racked up 42 of them across a single apartment complex.

Every Apartment the EPA Found in Violation

Below is the complete list of deficient lease files documented by the EPA during its May 2022 inspection. A checkmark indicates the violation was present in that apartment’s file.

Legal Receipts: The Document Speaks

These are direct passages from the EPA’s Consent Agreement and Final Order. These are not allegations. This is what the federal government documented and Woodner agreed to resolve.

“In 1992, Congress passed the Act in response to findings that low-level lead poisoning was widespread among American children, that pre-1980 American housing stock contained more than three million tons of lead in the form of lead-based paint, and that the ingestion of household dust containing lead from deteriorated or abraded lead-based paint was the most common cause of lead poisoning in children.” EPA Consent Agreement, Paragraph 1 — Statutory and Regulatory Authority

“40 C.F.R. § 745.113(b)(4) – A statement by the lessee affirming receipt of the information required… and the lead hazard pamphlet required under 15 USC § 2686. This statement allows the EPA to ascertain that the lessee has actually been informed of the risks of lead-based paint at the property.” EPA Consent Agreement, Paragraph 11 — EPA Findings of Facts and Conclusions of Law

“40 C.F.R. § 745.113(b)(6) – The signatures of the lessors, agents, and lessees certifying to the accuracy of their statements, to the best of their knowledge, along with the dates of signature. These signatures commit the parties to the lease transaction to the truth of statements made about lead-based paint, providing another avenue for the EPA to verify compliance with the disclosure requirements.” EPA Consent Agreement, Paragraph 11 — EPA Findings of Facts and Conclusions of Law

“Each of Respondent’s failures to comply with the requirements of the Disclosure Rule as identified above, constitutes an independent violation of TSCA and the Act for which penalties may be individually assessed.” EPA Consent Agreement, Paragraph 12

“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, lessor must disclose the presence of LBP and/or LBP hazards in the dwelling. Lessees must also receive a federally approved pamphlet on lead poisoning prevention.” Compliance Plan Appendix A, Section 6.0 — The mandatory Lead Warning Statement Woodner was required to include in every lease

Societal Impact: Who Pays When Landlords Cut Corners

What the Fine Could Have Been vs. What Woodner Actually Paid

Federal law capped the per-violation penalty for Lead Disclosure Rule violations at $22,263 per violation (as adjusted for inflation under the Debt Collection Improvement Act). With 42 independent violations, the maximum possible penalty was substantial. What Woodner actually paid tells a very different story.

The maximum statutory cap per violation is $22,263 (adjusted for inflation). Multiplied across all 42 documented violations, the maximum exposure was $935,046 (enough to pay one year of rent for roughly 25 working-class families in Yonkers). Woodner paid $59,500 (roughly what a minimum-wage worker in New York earns in two full years of labor), which is approximately 6.4 cents on every dollar the law allowed.