Wallace H. Campbell & Co. v. Maryland Commission on Human Relations, 33 A.3d 1042

Scarlett, a wheelchair user, mediated housing-dispute concerns with Campbell Company regarding Greenhill Housing.
The mediation occurred at Campbell Building, which lacked a wheelchair-accessible entrance despite some accessible facilities.
Neither Scarlett nor the mediator Belle nor Campbell requested any reasonable accommodation before the January 23, 2003 mediation.
Scarlett attended the mediation; accessibility issues were present but no accommodation was requested or confirmed by Campbell or Belle.
After mediation, the Commission investigated; initially, damages were denied, then later findings and penalties were issued, culminating in circuit-court petitions and enforcement actions.
The circuit court ultimately reversed and remanded the case for dismissal of charges, leading to Campbell’s appeal on statutory interpretation of 49B § 22(a)(9).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a prior request is required for § 49B-22(a)(9) to apply	Scarlett's lack of a request cannot foreclose liability due to knowledge of disability.	A refusal under § 49B-22(a)(9) requires a preceding request for accommodation.	Requires a prior request; there must be a request to constitute a refusal.

Schwarz v. City of Treasure Island, 544 F.3d 1201 (11th Cir. 2008) (plaintiff must actually request an accommodation and be refused)
Astralis Condo. Ass'n v. Sec'y, HUD, 620 F.3d 62 (1st Cir. 2010) (prior request required for failure-to-accommodate claim)
Marriott Emps. Fed. Credit Union v. Motor Vehicle Admin., 346 Md. 437 (Md. 1997) (deferential treatment of agency interpretations; statutory context)
Md. Aviation Admin. v. Noland, 386 Md. 556 (Md. 2005) (substantial evidence standard and administrative review)
Jaigobin, 413 Md. 191 (Md. 2010) (agency interpretations given deference; statutory interpretation is judicially reviewable)
Mehrling, 343 Md. 155 (Md. 1996) (statutory interpretation, context and purpose considerations)