The old 'panel in the shower' trick.
There are plenty of things wrong with this idea, but, code citations aside, I think the most worrysome is that it reveals the inverted sence of priorities that the remodeler and home owner had.
To them, the panel was a barely necessary evil, something that they really wish they didn't have to deal with.
"What's the worst that can happen? I pop a breaker, I just have to reach in and reset it."
When I moved to Nevada (From Chicago), I was surprised to see homes with all the breakers located outside at the service. (I had not seen an 'all-in-one' before). Until this very moment, I thought that was a pretty lame idea - the difficulties faced when adding circuits, the need to go outside at 3AM with a flashlight to reset one, etc.
Yet, thinking it over today ... all the efforts we see to hide, cover, tuck away panels. Placing them in closets and cupbords. On stairways and in halls. Behind furnaces, water heaters, and laundry equipment. I have to wonder if, maybe, putting the breakers outside - where the homeowner will prompltly place a big bush - is a better idea.
For those doing design work, all I can say is: put the panels behind the swing of a door. Operating the door will prevent anything else from getting placed there. It's the best I can figure out.