Author: JGL Law

Child custody orders in Maryland can be modified when there has been a material change in circumstances that affects the child’s well-being or the practicality of the current arrangement. Courts do not revisit custody simply because one parent is unhappy with the outcome. The focus is on whether something meaningful has changed and whether modifying the order serves the child’s best interests.

What Counts as a Material Change in Circumstances?

A material change is a development that significantly affects the needs of the child or the ability of one or both parents to meet the needs of the child. Courts look for changes that are ongoing and impactful, not temporary or minor.

Common examples include:

• A parent relocating or planning to relocate
• Changes in a child’s educational, medical, or emotional needs
• A shift in a parent’s work schedule that affects availability
• Domestic violence between the parents or toward a child
• Concerns about a child’s safety or well-being
• A breakdown in communication that makes the current arrangement unworkable

The key question is whether the change alters the foundation of the original custody decision. If the answer is yes, the court may consider modifying the order.

How Do You Modify a Child Custody Order in Maryland?

Modifying a custody order involves more than filing paperwork. You must present a clear legal basis for the request and support it with evidence.

The process typically includes:

• Filing a motion to modify custody with the court
• Identifying and explaining the material change in circumstances
• At trial, providing documentation or testimony that supports your position
• Participating in hearings or mediation, depending on the case

The court evaluates whether the existing order should be adjusted in light of new facts. This means your argument needs to be focused and tied directly to what has changed since the entry of the last custody order.

Does Your Proposed Change Meet Maryland’s Best-Interest Factors?

Once a material change in circumstances is established, the court must evaluate your proposed custody arrangement under the 16 best interest factors set out in Maryland Family Law § 9-201. Judges are required to address each factor on the record or in a written opinion, which means every factor will come into play in your case.

The factors cover a wide range of considerations, including:

• The child’s physical and emotional security and protection from conflict and violence
• Stability and the foreseeable health and welfare of the child, including the continuity of key relationships and routines
• The child’s day-to-day needs, such as education, medical care, and social development
• Each parent’s ability to co-parent, communicate, and place the child’s needs above their own

No single factor controls the outcome. Courts weigh all 16 factors together based on the specific circumstances of your family.

Timing and Evidence Matter in Modification Cases

When and how you seek a modification can affect the outcome. Courts generally expect that a change is established and ongoing, not speculative.

For example:

• A planned relocation may justify filing before the move occurs
• A temporary job change may not be enough without evidence that it will continue
• Concerns about a child’s well-being require documentation, not just allegations

Evidence can include school records, medical reports, communication logs such as Our Family Wizard, or testimony. The stronger and more consistent the evidence, the more likely the court is to take the request seriously and act on the request.

Common Challenges Parents Face

Custody modification cases are often contested and several issues come up repeatedly.

Parents may disagree about:

• Whether a material change has actually occurred
• How the change affects the child
• What arrangement would better serve the child’s needs

Courts are also cautious about repeated modification requests. If a similar request has already been denied, a new filing must be based on new developments, not the same arguments presented earlier.

Another common issue is relying on informal changes. Parents may adjust schedules between themselves, but unless those changes are formalized, the original order remains enforceable.

How Courts View Stability vs. Change

Courts value consistency and stability, especially for children. Even when circumstances shift, judges are careful about making changes that could disrupt the child’s routine without a clear benefit to the child.

This means that modification is not automatic, even when a change exists. The court balances:

• The need to respond to new circumstances
• The importance of maintaining consistency and stability for the child

A well-prepared case should address both sides of that balance. Custody modifications require more than showing that there has been some change since the last order. You need to connect that change to the legal standard the court applies and present a clear, supported argument.

Erika Jacobsen White was recognized by the U.S. District Court for the District of Maryland as a recipient of the inaugural Catherine C. Blake Exceptional Service Award.

The award honors her contributions as a member of the Local Rules Subcommittee on Appendix B, where her work supported the Court’s ongoing efforts to refine and strengthen its procedures.

Erika received the award at the Court’s Biennial Bench-Bar Conference on April 24, 2026.

You get a certified notice in the mail with “SHOW CAUSE ORDER” from your probate court. Your name is listed with a court date and time to appear, and a few words that something is missing or wrong with how you are handling your loved one’s estate.

You call the probate court trying to find out what you did. You are scrambling around to find a form to fix the problem. Or worse, you have ten other things that need to be done in your life. Surely, this can wait.

Think again. That dreaded Show Cause Order will turn into a Show Cause Order for Contempt and Removal of Personal Representative.

Common Problems That Result in a Show Cause Order

Most times the probate court is issuing a Show Cause Order to get you as the executor or personal representative to do something or correct a filing. These are the most common mistakes:

• You forgot to file an Inventory listing the estate’s assets
• You forgot to file a semi-annual accounting
• You did not include proper documentation for your inventory or accounting
• Your calculations are wrong and need correction
• You did not include a certificate of service
• You did not sign the inventory or accounting

Most times, just correcting the error takes the Show Cause Order off the court’s docket. But, if you do not know what to correct or fix, that Show Cause Order can snowball into something bigger like a bench warrant or your removal as executor.

How to Get Back on Track

If you do not have legal representation, your best course of action is to hire an experienced estate attorney who is knowledgeable about the estate administration process and who can help you get your administration back on track.

When faced with a Show Cause Order, it’s important to go back to the estate file and review all the documents. Most times, the court or register will issue a notice in advance of what filings need to be completed. It’s important to note these filings and their respective deadlines.

You want the court to know that you are taking your job as executor seriously. Most courts look favorably at the following:

• Having an attorney enter the case on your behalf
• Showing up to any court hearing if you cannot ask for a postponement well before the hearing
• Requesting an extension of time for filing
• Filing amended inventories and accountings as soon as possible
• Filing supporting documents or missing certificates/schedules
• Setting up an appointment with the register’s audit department to review your filings to explain any defects
• Filing a petition for clarification of any complex matters such as an interpretation of a will, determination of value of assets, etc.

Most probate judges understand mistakes happen. Things can be corrected. Times can be extended. However, it’s important to be present, show-up and be accountable.

Risks of Show Cause Orders

A Show Cause Order, as scary as it sounds, is an opportunity to correct something usually in the estate administration process. What normally irritates judges is when you do not show up to the hearing or fail to complete the task that started the show cause hearing.

The most common result of not following through is removal as the personal representative, followed by the need for someone else to petition to become the successor personal representative at a higher bond premium, or for an attorney to be appointed by the court to perform the role.

Final Thoughts

Take the Show Cause Order seriously. Contact an experienced estate attorney to help you get through the hearing and make the corrections. Many lawyers can be retained for a limited purpose so you can budget the estate’s assets.

The alternative is that the court will remove you and appoint an attorney to do the job and get paid. However, getting your estate administration back on your terms sometimes requires hiring an attorney of your choosing rather than having the court appoint one on your behalf.

The Daily Record has selected Paul Riekhof to receive an inaugural Managing Partner Award.

The Managing Partners Awards honor managing partners and equivalent senior firm leaders in both the legal and financial sectors who demonstrate vision, integrity and measurable impact on their organizations and communities.

These leaders are recognized for their professional achievements, commitment to developing the next generation of talent and their meaningful contributions to their firms and the broader community. The honorees were selected by The Daily Record’s editorial team.

“The inaugural Managing Partners award recipients are outstanding leaders in law and finance. Their innovative thinking and dedication to their fields demonstrate their strong commitment to their organizations, communities and beyond,” said Suzanne Fischer-Huettner, managing director of BridgeTower Media/The Daily Record. “These accomplished professionals also provide invaluable guidance to the next generation of leaders through mentoring. We at The Daily Record are pleased to celebrate these stellar leaders in our community.”

Paul will be honored on June 9 at an awards celebration and featured in a special magazine insert in the June 10 issue of The Daily Record, which will also be available online.

National Highway Transportation Safety Administration – Put the Phone Away or Pay Campaign

The campaign reminds drivers of the deadly dangers and the legal consequences, including fines, of texting and other forms of messaging behind the wheel.

General

• Distracted driving comes in many forms, but texting and cell phone use while driving has become the most prevalent type of distracted driving.
• If you are expecting a text message or need to send one that can’t wait, pull over and park your car in a safe location before using your device.
• Designate your passenger as your “designated texter.” Allow them access to your phone to respond to calls or messages.
• Do not engage in social media scrolling or messaging while driving.
• Struggling to not text and drive? Activate your phone’s “Do Not Disturb” feature, or put your cell phone in the trunk, glove box, or back seat of your vehicle until you arrive at your destination.
• When you get behind the wheel, be an example to your family and friends by putting your phone away. Just because other people do it doesn’t mean texting and driving is “normal” behavior.
• If you see someone texting while driving, speak up. If your friends text while driving, tell them to stop.
• Listen to your passengers: If they catch you texting while driving and tell you to put your phone away, put it down.

Enforcement

• Law enforcement officers nationwide are working together to enforce texting and distracted-driving laws.
• Handheld phone use:
  • In 30 states, the District of Columbia, Puerto Rico, Guam, the Northern Mariana Islands, and the U.S. Virgin Islands, handheld phone use is prohibited while driving. This is a primary enforcement law, meaning an officer may cite a driver for using a handheld cellphone without any other traffic offense taking place.
• All cellphone use:
  • No state bans all cellphone use for all drivers, but 36 states and the District of Columbia ban all cellphone use by novice drivers, and 23 states and the District prohibit cellphone use by school bus drivers.
• Text messaging:
  • In 49 states, D.C., Puerto Rico, Guam, the Northern Mariana Islands, and the U.S. Virgin Islands, texting while driving is an illegal, ticketable offense. Drivers could pay a hefty fine and receive points on a driver’s license.
  • Remember, when you get behind the wheel, Put the Phone Away or Pay.

Get more information about the Put Your Phone Away or Pay campaign.

If you or someone you know has been involved in an accident, or death as a result of a distracted driver you can protect your legal rights. Experienced attorneys know how to get you fair compensation.

Get the facts. Get educated.

Operating Agreements are drafted when business owners are aligned on their mission and focused on growth. Fundamentals to any Operating Agreement include establishing capital contributions, ownership percentages, management structure, and profit sharing. Less attention is given when drafting the sections about disassociation, withdrawal, or termination of ownership interests.

Most business owners are choosing co-owners and investors who are committed, serious and focused on long-term business growth. Most capital contributions go towards setting up the business, such as licenses, permits, leases, equipment, staff, professional fees, etc. Most owners do not want to deal with co-owners who are planning an early exit, demanding their capital contribution back when the money has already been spent.

Breaking Down Exits

Business owners are not immune to the inevitabilities of life such as death, divorce, health deterioration, relocations, bankruptcy, etc. People change. Circumstances change. Operating Agreements are intended to streamline the procedures for these life changes; however, several fail to give structures to address these changes. Most Operating Agreements do the following:

• No voluntary withdrawals
• No procedures for forced buyouts
• Lack of value methodology for capital return
• No dispute resolution mechanisms in place

Furthermore, certain states limit the right to dissociate from an LLC or have statutory requirements not addressed in the Operating Agreement. States such as Texas or Wyoming prohibit Membership withdrawals, leaving the Operating Agreement or judicial action to resolve the issue.

Addressing Exits in the Operating Agreement

A well-drafted Operating Agreement should account for the following circumstances in light of the local state statutory requirements:

• Members choosing to leave the business early
• Irreconcilable dispute among business owners
• Death, incapacity, or divorce of a Member
• Members seeking to sell out their interest shares
• Bankruptcy or other financial insolvency issues of a Member
• Serious misconduct allegations of a Member that are detrimental to the LLC including incarceration of a Member

Each of these circumstances raises serious legal issues for the LLC that would be difficult to address with a one-size fits all general statement on member exits.

Establishing Business Valuations in the Operating Agreement

Conflicts often arise when business owners are trying to determine the actual value of their business ownership. Most Operating Agreements stick to a simple return of capital with no interest. This seems simple and straight-forward, provided that the LLC maintains the capital contributions as such. However, most businesses ebb and flow financially.

Some become significantly more profitable while others decline. Some common questions that can be resolved in the Operating Agreement are:

• Who determines the ownership value?
• What metrics are used to determine the ownership value?
• Are third-party appraisals required?
• How are disputes resolved?
• Who pays the costs for determining the value?

Without proper drafting and foresight, a Member withdrawal can be devastating to a business. Remaining business owners can lose time in negotiations or litigation and face unexpected fees over these matters.

Payment Terms Matter Just as Much as Price

Even when valuation is addressed, paying out the interest becomes problematic. Operating Agreements do not always address how these payouts will be funded. Issues of payout include:

• Whether payment is required in one lump sum or installments
• Whether interest incurs for installment plans
• Whether a security interest is granted in installment plans

Often these issues are addressed in negotiations; however, Operating Agreements or subsequent Buy-Sell Agreements can resolve these issues in advance.

Final Thoughts

Operating Agreements, with periodic review and amendments, can ensure that business owners are aligned with business owner exits. Clearly drafted provisions on owner exits can:

• Minimize disputes
• Preserve business continuity
• Protect relationships between business owners
• Provide a roadmap for difficult situations

Life changes are inevitable, but planning ahead with clearly drafted provisions on business owner exits can prevent financial strain on business owners and the LLC.

Divorce is rarely easy. It is an emotional rollercoaster, and when you add financial stress to the mix, things can get complicated fast. One of the most frustrating situations we see at our firm is when one spouse discovers that marital money, money that should have been saved for the family or split during the divorce, has been spent on someone else.

In the legal world, we call this “dissipation of marital assets.” If your spouse has been spending money on a paramour (an affair partner), you likely have a lot of questions. Is that money just gone? Can you get it back? How does the court handle this?

We believe that understanding your rights is the first step toward a fair outcome. In Maryland, the law has very specific rules about what counts as wasting money and how the court can fix the balance.

What exactly is dissipation?

At its simplest, dissipation happens when one spouse intentionally spends or uses up marital property for a purpose that has nothing to do with the marriage. This usually happens right around the time the marriage is breaking down or after the couple has already separated.

For it to count as dissipation in a Maryland court, the spending must meet a few criteria. It isn’t just about making a bad investment or buying a car you didn’t like. It is about moving money out of the “marital pot” so that the other spouse can’t get their fair share during the divorce.

When we talk about a paramour, the spending is almost always considered “non-family.” This includes things like:

• Paying for hotel rooms, flights or vacations for secret getaways
• Expensive dinners and drinks
• Gifts like jewelry, clothes, or electronics
• Paying for the other person’s rent or car loan

How do you prove your spouse wasted money?

In Maryland, the “burden of proof” is on you. This means if you are the one making the claim, you have to be the one to show the court the evidence. We believe that documentation is your best friend in these cases.

Does the court care about every single coffee or lunch?

Usually, no. Courts are looking for significant amounts of money or a clear pattern of spending that isn’t related to the family. To win a claim for dissipation, three elements typically must be established:

1. The money was spent on non-family items. If the money went to a girlfriend or boyfriend, this is usually easy to prove because that person is not part of the marital unit.
2. The spending was intentional. You have to show that your spouse spent the money on purpose to reduce the amount of property available to be split.
3. The timing matters. Most dissipation happens when the marriage is failing. If your spouse spent money on a hobby ten years ago when things were great, the court likely won’t count that. If they spent $10,000 on a diamond necklace for someone else two months before filing for divorce, that is a different story.

Once you show that the money was spent, the ball is in your spouse’s court. They have to explain to the judge why that spending was actually for a “family purpose.” If they can’t give a good explanation, the court can move forward with a remedy.

What is the ‘three-part test’ in Maryland?

Maryland courts use a specific framework to decide if dissipation occurred. We often walk our clients through this step-by-step so they know what to expect.

First, the court looks at whether the property was spent on something that didn’t benefit the family. Second, they look at whether it was done to reduce the funds available for the “equitable distribution” (the fair split) of assets. Finally, they look at the intent.

Unlike some other nearby jurisdictions, Maryland specifically requires “intent.” This means your spouse had to know what they were doing. They were intentionally wasting the money. This is why looking at bank statements and credit card bills is so important. We look for large withdrawals, transfers to accounts you don’t recognize, or charges at luxury stores for items you never saw.

What happens if the money is already gone?

This is the question we hear most often. “April, if they already spent the money at a casino or on a vacation with their new partner, how can I get it back?”

The answer is a “phantom asset.”

In Maryland, if a judge finds that your spouse dissipated assets, they treat that money as if it is still sitting in the bank account. For example, let’s say there is $100,000 left to split, but your spouse spent $20,000 on a paramour. The judge will do the math as if there is actually $120,000 to split.

When it comes time to divide the remaining property, the judge will give your spouse a smaller share to make up for the $20,000 they already “spent” on their affair. This is how the court levels the playing field. Even if the cash is physically gone, you still get your fair share of what should have been there.

Are there any exceptions?

Yes. Not every dollar spent during a separation is considered dissipation. People still have to live. We believe it is important to distinguish between “wasting money” and “living life.”

Common things that are NOT usually dissipation include:

• Reasonable living expenses: Paying rent, buying groceries, and keeping the lights on at a new apartment after moving out.
• Child expenses: Paying for the kids’ school, clothes, or sports.
• Legal fees: In many cases, using marital funds to pay for a divorce lawyer is considered a necessary expense, though this can sometimes be debated depending on the source of the funds.
• Ordinary business expenses: If your spouse runs a business and has normal costs, that isn’t dissipation.

However, if those “living expenses” become excessive, like renting a $10,000-a-month penthouse when you used to live in a modest home, the court might take a second look.

How do we start the process?

If you suspect your spouse is wasting money, the first step is usually “discovery.” This is a formal legal process where we ask for financial records. We can look at:

• Bank statements
• Credit card history
• Investment account activity
• Venmo, PayPal, or Zelle history

Sometimes, the evidence is hidden in plain sight. A “business trip” that includes a charge for two people at a romantic resort is a major red flag. A large cash withdrawal right before a weekend away is another.

We believe that the earlier you look into these things, the better. If you wait until the very end of your divorce to bring up dissipation, it can be harder to track down the records and prove the intent.

Why a friendly, strategic approach works best

Dealing with an affair is emotional. It is easy to want to “punish” the other person in court. However, Maryland is an equitable distribution state, not a “punishment” state. The court isn’t there to judge your spouse’s morals, but they are there to protect your financial interests.

Our goal is to stay focused on the numbers. We want to make sure you walk away from your marriage with the resources you need to start your next chapter. Whether that means keeping the house or getting a larger share of the retirement accounts to balance out the money your spouse spent, we are here to help you navigate that.

If you are worried about your financial future or think your spouse is hiding or wasting assets, let’s talk.

Many business owners, like yourself, take the right steps to form the business structure that works for them. Then, years down the line, you set up your estate plan, often transferring ownership to a trust to avoid probate. However, sometimes these pieces do not fit and can cause problems later on.

Most owners get one attorney to set up their business structure and treat it as a finished product. They get busy building their business to provide for their family. Then, they hire another attorney to draft an estate plan, which usually includes transferring ownership of a business into a trust without updating the business structure. The lack of coordination creates risk for the business and the family.

Where Disconnects Happen

• Listing individuals to inherit your business interest in your Will or Trust, but your business structure requires additional steps to transfer business interests.
• Naming individuals to your board of directors in your Will or Trust without properly amending your bylaws or operating agreement to authorize such appointments.
• Naming individuals to manage your business as officers, but diluting your ownership share to different family members who may oust your named successor.
• Naming children to inherit your business, but forgetting about the spousal election and a spouse taking the business away from your children.
• For professional businesses, not listing a qualified licensed professional to handle your cases in a succession plan forces your executor or trustee to find a qualified professional to handle your case work in case of death or disability.
• Listing business interest transfers in a Will or Trust without ensuring your business has properly approved such transfers upon death may force an involuntary removal from the business by other co-owners.
• Having a Business Succession Plan that does not align with your Will or Trust, forcing a future court battle for your family members to resolve.

Why It Matters

These disconnects can have real-life consequences for your loved ones after your death, such as:

• Heirs may inherit business interests but lose value on improper transfers.
• Co-owners of the business may be put into direct conflict with family members over the business operation.
• Probate proceedings may halt business operations if there are disputes of ownership.
• Liquidity in a business may be used to pay out family members, jeopardizing the business’s lifespan.
• Valuations of businesses during probate can trigger unforeseen tax consequences for the business and your loved ones.
• Higher risk for court intervention, appointing a Receiver to take over the business who is not aligned with your original purpose.
• Likely winding down of your business without a meaningful opportunity to sell.

Getting Things In-Sync

Retaining legal counsel well-versed in business organizations and estate planning and making all the necessary changes results in a coherent overall plan for your business and family. A well-structured plan often addresses the following:

• Whether business interests should be held directly, transferred to a trust, or have a beneficiary on a death instrument approved by your business.
• Ensuring your bylaws or operating agreement authorizes transfers to family members.
• Drafting succession plans for business governance and operations in case of an owner’s disability or death.
• Determining business valuations upon disability and death.
• Evaluating multi-state business operations and properties to ensure your plans comply with different state laws.

Revisiting Your Plans

Business owners should keep both their business plan and estate plans in mind when making any changes. Business owners should also revisit both plans whenever:

• Your business has grown or changed substantially to ensure your business governing documents are aligned with your current business operations and structure.
• Any major life events occur, such as divorce, marriage, children, etc.
• Your business expands into other states.
• The existing plans have not been reviewed in several years.

Final Thoughts

Your business plan and your estate plan should not operate independently. They are two parts of one strategy – your legacy.

Taking the time to ensure both plans align can prevent future disputes, preserve value, and ensure the business continues as you intended.

Three former employees of the Psychiatric Institute of Washington (PIW) have been indicted on charges of criminal negligence in connection with the death of a patient, according to an April 8, 2026 report by NBC News 4 Washington. Prosecutors allege the employees failed to provide care to a visibly distressed individual over a prolonged period.

The allegations described in the indictment echo concerns raised in a class action lawsuit filed by Joseph Greenwald & Laake against PIW and its parent company, Universal Health Services, Inc. (UHS). The complaint alleges a longstanding pattern of patient mistreatment and systemic failures at the facility.

Specifically, the lawsuit alleges widespread falsification of medical records, unlawful involuntary hospitalizations, failure to provide necessary treatment, chronic understaffing, and unsafe and unsanitary conditions. The case is being handled by attorneys Drew LaFramboise and Veronica Nannis.

While the criminal case centers on the conduct of individual employees, the civil lawsuit seeks to address broader institutional practices and corporate accountability, including allegations that UHS prioritized profits over the safety and wellbeing of patients.

These developments highlight ongoing concerns about patient safety at PIW.

Many people have heard of workplace discrimination laws like Title VII of the Civil Rights Act. But far fewer people know about another federal civil rights law that can be just as powerful: 42 U.S.C. § 1981.

Section 1981 is built on a simple principle: everyone has the same right to make and enforce contracts regardless of race. This law protects individuals from racial discrimination in contracts, business relationships, and professional opportunities.

For many people facing discrimination outside traditional employment, Section 1981 may provide the strongest legal remedy available. In many situations, Section 1981 fills critical gaps that other civil rights laws do not cover.

Below are some of the most common ways the law is used.

Discrimination in Business Relationships

Section 1981 frequently arises when racial discrimination affects contracts between businesses or professional service providers. In practice, many § 1981 cases involve minority-owned businesses or vendors who are denied contracts or removed from business relationships because of race. Unlike many employment statutes, § 1981 protects entrepreneurs, vendors, contractors, and business owners.

Examples may include:

• A company refusing to contract with a qualified minority-owned vendor while working with similarly situated non-minority vendors.
• A company terminating an existing subcontractor or vendor agreement after racial bias emerges.
• A minority-owned subcontractor is being removed from a project while non-minority subcontractors remain.
• A company refusing to negotiate or continue negotiations after learning the race of the business owner.
• A company offers a minority-owned vendor worse pricing or contract conditions than similarly situated vendors.

Because these relationships are contractual in nature, courts have consistently held that they fall within the core protections of § 1981.

For business owners and independent professionals, this statute may be one of the most important legal protections against race discrimination in the marketplace.

Discrimination Against Independent Contractors and Consultants

Section 1981 also protects individuals whose ability to pursue contract-based work relationships is limited by race discrimination.

Many professionals work as consultants, freelancers, and independent contractors, rather than employees. Because these relationships are contractual, § 1981 often applies even when traditional employment discrimination laws, such as Title VII of the Civil Rights Act, do not.

These cases sometimes involve situations where:

• A consulting agreement is terminated after discriminatory comments.
• A company refuses to renew or extend an independent contractor agreement for discriminatory reasons.
• A contractor is treated differently (such as an hourly rate or other contract terms) from similarly situated contractors of another race.

Additionally, in some industries, participation in professional networks or trade organizations is an important gateway to obtaining contracts and referrals. When race discrimination interferes with access to those opportunities, § 1981 may apply because it affects the individual’s ability to enter into business relationships.

Discrimination in Customer or Consumer Transactions

Section 1981 can also apply to discriminatory treatment in consumer-facing businesses. For example, courts have allowed claims where businesses:

• Refuse service because of a customer’s race.
• Provide services on worse terms, or subject customers to more burdensome conditions because of their race.
• Cancel or deny contracts for housing, services, or membership opportunities based on race.

These cases often arise in situations where a business relationship already exists, such as when a customer has purchased a product or service and the business refuses to honor the transaction because of racial stereotypes.

For example, one scenario recognized by courts is where a passenger purchases an airline or train ticket – a contract for transportation – but is removed from the flight or train based on racially-biased assumptions about the passenger’s behavior or safety risk. In a similar vein, courts have allowed § 1981 claims where retail stores refuse to complete a purchase or eject customers from the premises after they attempt to buy goods or services because of racial stereotypes.

Retail stores, banks, financial services companies, and other businesses that enter contractual relationships with customers may all be subject to § 1981.

If Race Discrimination Has Affected Your Business or Career

Race discrimination does not only occur in traditional workplaces. It can appear in contracts, partnerships, business opportunities, and professional relationships.

If you are a business owner, contractor, or professional who believes race discrimination affected a contract or business opportunity, you may have legal protections under federal civil rights law.

An experienced civil rights attorney can evaluate whether your situation may fall within federal civil rights laws such as 42 U.S.C. § 1981.

In this episode of JGL LAW FOR YOU, David Bulitt and family law attorney Christopher Castellano discuss the growing reality of “gray divorce” (divorce later in life) and why it often brings a very different set of challenges. From retirement accounts, pensions, and alimony to the future of the family home, adult children’s involvement, and estate planning concerns, David and Chris walk through the key issues that can shape a divorce after the age of 55. Whether you are facing a late-in-life separation or simply want to understand the legal landscape, this episode offers practical insights into one of family law’s most complex and increasingly common situations.

In an article published by Law.com on March 25, 2026, Christopher Castellano discusses recent changes to Maryland’s child support framework, including the adoption of the Multifamily Adjustment, which took effect October 1, 2025.

Chris explains that the update is not intended to reinvent Maryland’s child support system, but rather to refine it to better reflect modern family structures. Maryland continues to rely on a formula-based approach that uses parents’ income and certain child-related expenses to calculate a presumptively correct child support award.

He also notes that while the guidelines are standardized, disputes often arise over how key inputs—such as a parent’s actual income or physical custody arrangements—are defined and applied. With the addition of the Multifamily Adjustment, which accounts for children living in a parent’s household who are not part of the support order, those interpretations may take on greater importance in future cases.

A central theme of the framework, Chris emphasizes, is the continued focus on children’s welfare. “It is in this best-interests backstop that the ever-present goal of the Maryland legislature remains apparent: the preservation and consideration of that which is in the best interests of the minor child in question,” he said.

Read the full article “Maryland Child Support Law in 2026: A Guidelines System Adapts to Blended Families” (PDF)