Arelis Araujo v. New York City Department Of Education

Background

Cynthia Ramos filed a motion asking the court to reconsider its March 18, 2024, order. The underlying dispute concerned transportation for her daughter, W.R., to and from iBRAIN, a special-education school, during the 2021–2022 extended school year.

An administrative decision required the school district to pay transportation costs at the lower of the Medicaid rate or a fair-market rate supported by comparable transportation. After earlier proceedings, the court initially awarded Ramos $7,500 for twenty trips at $375 per trip. The court then reconsidered that award at the Department of Education’s request and reduced it to $433.80, using a Medicaid rate of $21.69 per trip from the 2018 Preschool/School Supportive Health Services Program Medicaid handbook.

Arguments and analysis

Ramos argued that the 2018 handbook was outdated and did not apply. She relied on a 2023 Medicaid transportation policy manual, which discusses negotiated reimbursement rates for transportation providers, and argued that the court should use the prevailing market rate instead. The Department of Education argued that the reconsideration motion was untimely, improperly attempted to relitigate an earlier issue, and challenged the rate used in the March 18 order.

The court found the motion timely under the federal rules governing alteration of a judgment and relief from an order. But reconsideration under Rule 59(e) requires a clear legal error or manifest injustice, and relief under Rule 60(b) generally requires exceptional circumstances and highly convincing evidence.

The court determined that the 2023 manual concerned transportation to medical appointments and services, not education-related transportation for students with disabilities. In contrast, the 2018 handbook specifically covered special transportation as a Medicaid-reimbursable service under the school-supportive health-services program. Although neither party definitively established whether the 2018 handbook was in effect during the relevant period, the court took judicial notice that it remained the version linked on the state education agency’s website and concluded that its rates were apparently in effect during the 2021–2022 school year.

The court also rejected Ramos’s arguments challenging the administrative decision’s use of the lower of the Medicaid rate or fair-market rate. It held that those arguments challenged the merits of the administrative decision and could not be raised because Ramos had not exhausted the required administrative remedies.

Ruling

Judge Lorna G. Schofield held that Ramos had not shown a clear legal error under Rule 59(e), highly convincing evidence, or exceptional circumstances under Rule 60(b)(1). The court therefore ordered that Ramos’s motion for reconsideration be DENIED and directed the clerk to close the motion at Docket 152.