An Eight-Part Investigative Series
In 2013, a Maryland custody case called Reichert v. Hornbeck entered the state’s official legal record as a published appellate opinion — a decision courts could cite, attorneys could rely on, and students could study.
The case kept going. For another twelve years, across five more appeals, the Appellate Court of Maryland continued to resolve disputes between Jeffrey Reichert and Sarah Hornbeck: disputes over protective orders, emergency custody modifications, parental alienation, contempt, venue, and child abuse. Each appeal produced a written opinion.
Not one was published.
This series examines those five unreported opinions — what they decided, what legal questions they resolved, and what it means that none of their reasoning entered the public record. It also examines the broader question those opinions raise: why the cases that matter most to Maryland families consistently produce the least public law.
Maryland Rule 8-605.1 gives the Appellate Court unreviewable discretion to decide what is “of substantial interest as precedents.” This series asks whether that discretion is being exercised in a way that serves the people the courts exist to protect.
Why This Series Matters
Family court decisions determine where children live, whether parents see them, and how abuse is defined under the law.
Yet these cases rarely produce published precedent — even when appellate courts resolve complex and recurring legal questions.
In Reichert v. Hornbeck, five appellate decisions addressed issues that arise in courtrooms across Maryland every day. None were published. None can be meaningfully cited.
This series examines what that means — not just for one case, but for the development of family law itself.
The Series
Article 1 — The Introduction Five Appeals, No Precedent: How One of Maryland’s Most Litigated Custody Cases Disappeared Into the Shadows What unreported means, why it matters, and the scope of what was lost.
Article 2 — Opinion 1 (No. 0625, filed March 18, 2022) The Standard Nobody Published: Maryland’s Amended Protective Order Law, Eight Years Without a Reported Case
Article 3 — Opinion 2 (No. 0125, filed September 12, 2022) The 90-Day Order: How an Unprecedented Custody Decision Became Invisible Law
Article 4 — Opinion 3 (No. 1370, filed June 2, 2023) When Parental Alienation Becomes Child Abuse, and No One Can Cite It
Article 5 — Opinion 4 (No. 159, filed May 13, 2025) Filed in Baltimore, Decided in Annapolis: The Venue Question That Keeps Disappearing Into Unreported Opinions Coming soon.
Article 6 — Opinion 5 (No. 602, filed January 20, 2026) The Last Appeal: How a Contempt Hearing Became a Custody Modification, and What That Means for Maryland Law Coming soon.
Article 7 — The Pattern Piece One Judge, Five Years, No Precedent: The Structural Story Behind the Shadow Docket Coming soon.
Article 8 — The Broader Implications Maryland’s Invisible Family Law: Why the Cases That Affect the Most People Produce the Least Public Law Coming soon.
Source Documents
All source documents referenced in this series were obtained through publicly available records. Primary sources include:
- The five unreported opinions, available through the Maryland Judiciary Case Search
- Appellate briefs filed with the Appellate Court of Maryland
- Circuit court orders and dockets from Case Nos. C-02-FM-20-001706, C-02-FM-24-812286, and related cases
- The 2013 reported opinion, Reichert v. Hornbeck, No. 0213, September Term 2012
- Maryland Rules 8-605.1 and 1-104
The Maryland Judiciary Case Search is accessible at casesearch.courts.state.md.us.
The Appellate Court of Maryland was asked for comment on the publication designations discussed in this series. No response was received prior to publication.
Riptide Investigations examines where power operates without transparency — and what happens to the people caught inside those systems.
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