Home » Blog » Two Courts, Two Answers: How a Federal Accommodation Order Exposed the Anne Arundel Circuit Court’s ADA Defiance

Two Courts, Two Answers: How a Federal Accommodation Order Exposed the Anne Arundel Circuit Court’s ADA Defiance

Graphic comparing two legal venues: United States District Court and Anne Arundel County Circuit Court, focusing on issues of PTSD and ADA accommodations.

A federal magistrate judge granted Jeff Reichert ADA accommodations in January 2026. The Anne Arundel County Circuit Court — named as a defendant in a related federal civil-rights suit — kept saying no. This is what the documents show.

By Michael Phillips | RiptideThe Reichert Files


On January 13, 2026, United States Magistrate Judge J. Mark Coulson issued a ruling that should have settled the question, at least for any proceeding under his jurisdiction. Jeff Reichert — an Army veteran diagnosed with service-connected Post-Traumatic Stress Disorder and Traumatic Brain Injury — was entitled to appear remotely for all pretrial matters in his federal malicious prosecution case. The ruling was grounded in Section 504 of the Rehabilitation Act and the practical realities of adversarial legal proceedings. It was, by any conventional legal measure, unremarkable. Courts routinely grant remote appearance accommodations to disabled litigants.

What made the order remarkable was its context.

At the same moment Judge Coulson was granting that accommodation in Reichert v. Hornbeck (Case No. 1:24-cv-01865), the Circuit Court for Anne Arundel County was running in the opposite direction. Over the course of roughly 18 months, according to filings reviewed by Riptide, that court had denied Reichert’s ADA accommodation requests at least six times, conducted multiple hearings without his participation, and — in an extraordinary administrative step — ordered him to stop filing accommodation requests altogether. A judge, according to those filings, told him he was permanently barred from submitting future ADA requests in that court.

The contrast between the two courts’ responses to the same man, the same disabilities, and the same type of request — remote participation — frames a question that goes beyond Reichert’s custody dispute: what does the Americans with Disabilities Act actually mean when a court decides it doesn’t want to comply?

A comparison of two court cases regarding disability accommodations, showing contrasting results from the U.S. District Court and Anne Arundel County Circuit Court. The U.S. District Court accepted a PTSD diagnosis as credible and granted remote access, while the Circuit Court denied accommodations without explanation.

The Federal Order

Magistrate Judge Coulson’s January 13 memorandum opinion is careful and measured — precisely the kind of ruling that makes the Anne Arundel record look worse by comparison. Reviewing Reichert’s motion under both Rule 43(a) of the Federal Rules of Civil Procedure and Section 504, the court found that Reichert had presented documented PTSD and related diagnoses, and that for pretrial matters — hearings, conferences, depositions — remote participation is routinely available and imposes minimal burden on any party.

From the Record — Reichert v. Hornbeck, ECF No. 77 (D. Md. Jan. 13, 2026)
The court granted Reichert’s motion as to discovery and pretrial matters, permitting appearance by videoconference or telephone at Reichert’s election. The court noted the absence of any specifically articulated objection from the opposing party to this relief, and observed that such proceedings are “routinely conducted by remote means even in the absence of such diagnoses.”

The court did draw a line: it declined to extend the accommodation to Reichert’s live trial testimony, reasoning that Fed. R. Civ. P. 43(a) sets a high bar for remote testimony in open court and that Reichert had not demonstrated the kind of “good cause in compelling circumstances” required. That portion of the ruling was a measured legal distinction, not a repudiation of Reichert’s disability claims. The court accepted his diagnoses and acknowledged the validity of his accommodation needs; it simply found the trial-testimony request went further than the law required.

On the pretrial question — the same accommodation Reichert had been seeking in Anne Arundel County for years — a federal judge said yes within weeks of the motion being filed.

What Anne Arundel Said

The Anne Arundel County Circuit Court record, reconstructed from filings in the related federal civil-rights action Reichert v. Anne Arundel County Circuit Court et al. (Case No. 1:25-cv-04289, D. Md.), tells a different story. According to Reichert’s administrative complaint to the U.S. Department of Justice and his federal complaint — both based on documentary filings — the pattern began in at least 2020 and continued without resolution through the end of 2025.

November 2024: Reichert filed a request to appear remotely at a contempt hearing. The court denied it with no written explanation and proceeded without him. December 2024: An ADA advocate, Jay Shore, attempted to file on Reichert’s behalf. The clerk’s office turned him away. Reichert filed again; the court again denied the request the day of the hearing, again without explanation, and proceeded in his absence. June 2025: Reichert filed for a custody hearing. An ADA advocate, Janice Wolk-Grenadier, filed independently on his behalf. The court denied all of her applications. The accommodation was denied at the start of the hearing, and the hearing proceeded.

Chart detailing accommodation requests and denials from 2020 to 2026 in the case Reichart v. Hornbeck at the Anne Arundel County Circuit Court.

Then, in July 2025, something unusual happened. Judge Donna Schaeffer reportedly went beyond denying the pending accommodation request and ordered Reichert never to file another ADA accommodation request in that court. That directive — if accurately described in Reichert’s filings — would represent a per se violation of Title II of the ADA and its anti-retaliation provision, 42 U.S.C. § 12203, which prohibits adverse actions against individuals for asserting disability rights.

From the Record — DOJ Administrative Complaint, December 1, 2025
Filed under Title II, 42 U.S.C. § 12131–12134, Reichert alleged that the court “had actual and constructive knowledge of my disability and accommodation needs through repeated filings and communications; nevertheless, it continued to deny or obstruct accommodations.” The complaint identified at least seven distinct denial events and requested a DOJ investigation, remedial ADA policies, and designation of a formal ADA coordinator with a published request process. DOJ Record No. 679335-FQC.

The DOJ declined to investigate, but — and this matters legally — expressly declined to determine that the complaint lacked merit. That distinction formed part of Reichert’s theory of jurisdiction when he filed his federal civil-rights complaint on December 30, 2025: private enforcement was appropriate because the federal agency left the question open.

The Federal Lawsuit and Its Fate at the TRO Stage

The federal civil-rights complaint in Case No. 1:25-cv-04289 named the Anne Arundel County Circuit Court, the Chief Administrative Judge in her official capacity, and Court Administration/ADA Officials. It alleged two counts: a Title II ADA violation for systematic denial of accommodations and exclusion from judicial proceedings, and a retaliation claim under 42 U.S.C. § 12203 based on the prohibition on future ADA filings.

Crucially, the complaint was drafted narrowly. It sought no merits adjudication of the underlying custody case. It sought only prospective, ADA-compliant access to court proceedings and protection from retaliation. This framing was deliberate: courts have occasionally declined to reach the ADA access question in family court cases by treating it as an extension of the domestic-relations matter itself. The complaint anticipated that argument and explicitly disclaimed it.

The accompanying Emergency Motion for a Temporary Restraining Order did not survive initial review. U.S. District Judge Matthew J. Maddox denied the ex parte TRO request on December 31, 2025, finding that Reichert had not identified a specific imminent proceeding in Anne Arundel County at which he would be denied access without accommodation, and had not complied with Rule 65(b)(1)(B)’s requirement to certify efforts to notify the opposing party or explain why notice should not be required. The court did not reach the merits of the ADA claims.

From the Record — Order Denying TRO, ECF No. 4 (Dec. 31, 2025)
Judge Maddox: “Although the Court does not discount hardships Plaintiff has experienced, it is not clear what immediate and irreparable harm would be prevented by a temporary restraining order such that emergency relief is necessary before Defendants can be practicably heard in opposition to his Motion.”

The denial was procedural, not substantive. The ADA civil-rights case itself remained pending.

Back in State Court, Armed With a Federal Order

On January 20, 2026 — one week after the federal accommodation order in Reichert v. Hornbeck — Reichert filed a cluster of documents in the Anne Arundel County Circuit Court, appearing pro se following the withdrawal of his counsel. Three filings landed on the same day.

The first was an Emergency Notice of Self-Representation, formally entering his appearance in the custody matter, Case No. C-02-FM-25-000493. The second was an Emergency Motion for Remote Appearance as Reasonable Accommodation Under the ADA, citing the January 13 federal order from Judge Coulson directly and arguing that denying the same accommodation in state court would contradict a federal judicial determination of his disability rights, perpetuate the very conduct alleged in the pending federal ADA complaint, and raise the appearance of retaliation. The third was an Emergency Motion to Prohibit Dismissal for Non-Appearance, asking the court not to dismiss the case or penalize him for non-attendance at the upcoming pre-trial conference while his ADA motion was pending.

From the Record — Emergency Motion for Remote Appearance, Jan. 20, 2026
“On January 13, 2026, in Reichert v. Hornbeck, Case No. 1:24-cv-01865 (D. Md.), United States Magistrate Judge Mark Coulson entered a Memorandum Opinion and Order granting Plaintiff the right to appear remotely for all pretrial matters, including hearings and conferences, as a reasonable accommodation for PTSD. Denial of remote participation in this case would therefore: (a) Contradict a federal court’s adjudication of Plaintiff’s ADA rights; (b) Perpetuate the very conduct alleged in the pending federal complaint; and (c) Create the appearance of retaliation for seeking federal enforcement of disability rights.”

The filings placed the Anne Arundel Circuit Court in a difficult posture. A federal magistrate judge had contemporaneously assessed the same disability, the same accommodation type, and the same factual predicate — and granted the relief. Any denial of the January 20 motion by the state court would now exist in direct documentary contrast with a federal judicial order.

A Pattern the Documents Establish

Taken together, the record that has accumulated in this case is unusual in its specificity. This is not a case where a disabled litigant alleges vaguely that a court was unresponsive. The filings show: written denial orders with no stated rationale; hearings that proceeded in Reichert’s absence after accommodation was denied the day of the proceeding; a clerk’s office that turned away a credentialed ADA advocate; and a judicial directive — if Reichert’s account is accurate — prohibiting future accommodation requests entirely.

The applicable legal standards are not ambiguous. Title II of the ADA, as interpreted by the Supreme Court in Tennessee v. Lane, 541 U.S. 509 (2004), requires public entities — including state courts — to ensure meaningful access to judicial services. Denials must be accompanied by an explanation showing why the accommodation is unreasonable. Proceeding with hearings after an accommodation request is pending — without written denial and without the required interactive process — is not a defensible posture under the statute or its implementing regulations at 28 C.F.R. Part 35.

Flowchart detailing the legal framework of the case Reichert v. Anne Arundel County Circuit Court, including claims under the Americans with Disabilities Act, specifically Count I regarding Title II and Count II for Retaliation.

The retaliation angle, if supported, is legally more serious. Barring a party from submitting accommodation requests is precisely the kind of adverse action that 42 U.S.C. § 12203 prohibits. A court that tells a disabled litigant to stop asserting federal rights has not simply failed to comply with the ADA — it has, according to the statute, retaliated against the exercise of protected conduct.

What Comes Next

The federal civil-rights case, Reichert v. Anne Arundel County Circuit Court et al., remains active in the U.S. District Court for the District of Maryland before Judge Maddox. The underlying state custody matter, Reichert v. Reichert and Hornbeck, Case No. C-02-FM-25-000493, continues in Anne Arundel County — the same court that is a named defendant in the federal suit.

What the January 2026 filings accomplished, whatever the state court’s response, is to create a documentary record that now spans two federal courts and one state court, spanning roughly five years of accommodation requests, denials, and escalating legal filings. A federal judge has assessed Jeff Reichert’s PTSD diagnosis, found it credible and legally sufficient to warrant pretrial accommodations, and said so in a written order. Whether the Anne Arundel County Circuit Court responds differently this time — with the federal order in hand and a pending civil-rights lawsuit naming it as a defendant — is the question the record has been building toward.


This story is part of The Reichert Files, Riptide’s ongoing investigation into the Reichert custody case and the systemic questions it raises about due process, disability rights, and family court accountability.


Source Documents
Reichert v. Anne Arundel County Circuit Court et al., Case No. 1:25-cv-04289-MJM (D. Md.): Complaint (ECF No. 1), Emergency Motion for TRO (ECF No. 2), Exhibits 2-1 through 2-4, Clerk’s Notice (ECF No. 3), Order Denying TRO (ECF No. 4). Reichert v. Hornbeck, Case No. 1:24-cv-01865-JMC (D. Md.): Memorandum Opinion and Order on Accommodations (ECF No. 77, Jan. 13, 2026). Anne Arundel County Circuit Court, Case No. C-02-FM-25-000493: Emergency Notice of Self-Representation (Jan. 20, 2026), Emergency Motion for Remote Appearance (Jan. 20, 2026), Emergency Motion to Prohibit Dismissal (Jan. 20, 2026). U.S. Department of Justice ADA Administrative Complaint, DOJ Record No. 679335-FQC (Dec. 1, 2025).


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About Michael Phillips

Michael Phillips is a journalist, editor, creator, IT consultant, and father. He writes about politics, family-court reform, and civil rights.

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