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Morton v. Ruiz

Supreme Court of United States
415 U.S. 199 (1974)
ELI5:

Rule of Law:

An administrative agency cannot deny benefits to individuals based on an internal eligibility rule that was not published pursuant to the Administrative Procedure Act, especially when the agency has consistently represented a broader scope of eligibility to Congress during the appropriations process.


Facts:

  • Ramon and Anita Ruiz, Papago Indians, left the Papago Reservation in Arizona in 1940 to seek employment.
  • They settled in an 'Indian Village' in Ajo, Arizona, 15 miles from the reservation, where they lived continuously.
  • The Ruizes were unassimilated into the dominant culture and maintained close economic and social ties with the Papago Reservation.
  • In July 1967, the mine where Mr. Ruiz worked was shut down by a strike, leaving him with a sole income of $15 per week in union benefits.
  • Mr. Ruiz was denied welfare assistance from the State of Arizona due to his status as a striking worker.
  • On December 11, 1967, Mr. Ruiz applied for general assistance benefits from the Bureau of Indian Affairs (BIA).
  • The BIA denied his application solely because its internal manual limited eligibility to Indians living 'on reservations', and the Ruizes lived outside the reservation's physical boundaries.

Procedural Posture:

  • Ramon and Anita Ruiz initiated a class action lawsuit against the Secretary of the Interior in the United States District Court for the District of Arizona.
  • The District Court dismissed the complaint on cross-motions for summary judgment.
  • The Ruizes, as appellants, appealed the dismissal to the United States Court of Appeals for the Ninth Circuit.
  • The Court of Appeals reversed the District Court's judgment, finding the BIA's residency limitation inconsistent with the Snyder Act.
  • The Secretary of the Interior, as petitioner, was granted a writ of certiorari by the Supreme Court of the United States.

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Issue:

Does the Bureau of Indian Affairs' (BIA) internal policy, which denies general assistance benefits to otherwise eligible Indians who live near but not on a reservation, violate federal law where the BIA has consistently represented to Congress that its services extend to Indians 'on or near' reservations and has not published its restrictive eligibility rule in the Federal Register?


Opinions:

Majority - Mr. Justice Blackmun

Yes, the Bureau of Indian Affairs' internal policy violates federal law. The Snyder Act and relevant appropriations acts do not contain any geographic limitation on general assistance benefits. The BIA consistently represented to congressional appropriations subcommittees that its service population included Indians living 'on or near' reservations, leading Congress to appropriate funds with that understanding. Furthermore, the BIA failed to publish its restrictive 'on reservation' eligibility rule in the Federal Register as required by the Administrative Procedure Act (APA) for substantive rules affecting individual rights. Because the BIA did not follow its own procedures or those of the APA, its unpublished, internal rule is ineffective to deny benefits to a class of beneficiaries whom Congress was led to believe would be covered.



Analysis:

This decision is a cornerstone of administrative law, reinforcing the principle that agencies are bound by their own procedural rules and the mandates of the Administrative Procedure Act. It establishes that an agency cannot rely on an unpublished, internal policy to deny substantive rights or benefits, particularly when that policy is inconsistent with the agency's representations to Congress. For federal Indian law, the case highlights the government's trust responsibility, requiring fair and transparent dealing with Native American populations. The ruling pressures federal agencies to be explicit and public with their eligibility criteria, preventing the use of 'secret law' to the detriment of potential beneficiaries.

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