Morton v. Ruiz
Headline: Court allows federal general assistance for unassimilated Indians living in Indian communities near reservations, blocks unpublished BIA residency rule, and sends case back for benefits determination.
Holding: The Court held that Congress’s appropriation covered Indians living 'on or near' reservations like a Papago Indian family, affirmed the appeals court, and ruled the BIA may not deny benefits by an unpublished internal rule.
- Makes needy Indians living near reservations eligible for BIA general assistance.
- Prevents use of unpublished internal manuals to deny benefits.
- Requires Interior to publish eligibility rules before cutting off benefits.
Summary
Background
A Papago Indian couple lived since 1940 in an Indian Village in Ajo, about 15 miles from their Papago Reservation, and depended on mine work until a 1967 strike cut their income. They applied to the Interior Department’s Bureau of Indian Affairs (BIA) for general assistance in December 1967 but were denied because an internal BIA Manual said benefits were limited to Indians living "on reservations" (with narrow exceptions for Alaska and Oklahoma). A federal trial court dismissed their suit; the Court of Appeals reversed, and the Supreme Court agreed to decide the matter.
Reasoning
The main question was whether Congress’s annual appropriation and the BIA’s long practice were meant to exclude needy Indians who live in closely connected Indian communities just off the formal reservation. The Court found that the BIA repeatedly told Congress it served Indians "on or near" reservations, and that the Manual’s strict "on reservations" wording was not published or enforced consistently. Because the BIA had not made the residency rule a published policy under its own procedures and the Administrative Procedure Act, the agency could not quietly deny benefits to otherwise eligible, unassimilated Indians who maintain close ties to the reservation. The Court affirmed the appeals court on this narrower statutory ground and sent the case back for a determination of who in the plaintiffs’ class qualifies.
Real world impact
The decision means that needy Indians living in Indian communities near reservations — who remain culturally and economically tied to the reservation — can be covered by the BIA general assistance program. It also requires the Interior Department to publish and follow formal eligibility procedures before denying benefits; the Court did not decide any constitutional claims raised by the plaintiffs.
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