Arroyo v. John J. Rhodes
- Karas
- 7:26-cv-01558
- U.S. District Court · Southern District of New York
- 5
In Noel Arroyo v. Rhodes, Judge Karas denied reconsideration of an order denying Arroyo’s request for emergency relief over a hydration bottle during court proceedings.
The ruling affects Noel Arroyo’s request to reconsider the denial of emergency injunctive relief requiring defendants to let him keep a hydration device during court proceedings.
What happened
In Noel Arroyo v. John J. Rhodes, et al., Noel Arroyo asked the court to reconsider its earlier denial of his request for a temporary restraining order and preliminary injunction. He argued that his disability required immediate access to a hydration bottle during court proceedings and that retrieving it from courthouse security would cause harmful delays.
Arroyo said he had experienced a dehydration episode during a January 14, 2026 proceeding after security confiscated his bottle. He argued that the offered arrangement did not provide meaningful access to court services under Title II of the Americans with Disabilities Act and asked to keep the bottle during proceedings, subject to security inspection.
Judge Kenneth M. Karas denied the application. The court concluded that Arroyo had not identified facts or arguments it previously overlooked that could change its decision. The court also noted that he had not identified a future court date, shown that he qualified under the Americans with Disabilities Act, or explained why a plastic water bottle was not an effective accommodation.
The detailed version
- Arroyo v. John J. Rhodes · No. 7:26-cv-01558
- Karas
- July 15, 2026
Background
Noel Arroyo moved for reconsideration of the court’s earlier order denying his motion for a temporary restraining order and preliminary injunction. He relied on Federal Rules of Civil Procedure 54(b), 59(e), and 60(b), as well as Local Civil Rule 6.3.
Arroyo argued that the court had overlooked facts about the seriousness of his disability and the risk of irreparable harm—harm that cannot be adequately repaired later with money damages. He said that sudden dehydration episodes required immediate access to water and that he was receiving treatment from a licensed therapist.
Arroyo described an episode during a January 14, 2026 court proceeding, when courthouse security had confiscated his medically necessary hydration bottle. He said that retrieving the bottle from security caused a significant delay and increased his medical distress. He argued that repeatedly leaving the courtroom to retrieve the bottle would interrupt proceedings and prevent equal participation.
Arroyo relied on Title II of the Americans with Disabilities Act, which he said requires public entities to provide meaningful access to court services. He asked the court to allow him to keep the hydration device during court proceedings, subject to reasonable security inspection. He also requested permission to submit additional medical records under seal or through another protective procedure if the court required more documentation.
Court’s reasoning
The court explained that reconsideration motions have a strict standard. Such a motion must identify matters or controlling decisions that the court overlooked and that could reasonably be expected to change the result. The court stated that reconsideration is not a way to relitigate old issues or take a second opportunity to present them.
The court found that Arroyo had not raised allegations or arguments that it had overlooked when deciding that he had not shown a likelihood of irreparable harm or success on the merits. The court specifically identified three deficiencies: Arroyo had not identified a future court date, had not demonstrated that he was a qualified individual under the Americans with Disabilities Act, and had not explained why a plastic water bottle was not an effective accommodation.
Disposition
Judge Kenneth M. Karas denied the application for reconsideration. The Clerk of Court was directed to terminate ECF No. 40.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.