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Law School Case Brief

Morton v. Ruiz - 415 U.S. 199, 94 S. Ct. 1055 (1974)

Rule:

The Bureau of Indian Affairs (BIA) Manual provides that the purpose of the general assistance program is to provide necessary financial assistance to needy Indian families and persons living on reservations under the jurisdiction of the BIA and in jurisdictions under the BIA in Alaska and Oklahoma. Eligibility for general assistance is limited to Indians living on reservations and in jurisdictions under the BIA in Alaska and Oklahoma.

Facts:

Respondent Ruiz and his wife, Papago Indians, left their reservation in Arizona in 1940 to live in an Indian community a few miles away and Ruiz found employment at a nearby mine. During a prolonged strike, Ruiz applied for but was denied general assistance benefits under the Snyder Act by the Bureau of Indian Affairs (BIA) because of a provision in the BIA Manual limiting eligibility to Indians living "on reservations" (and in jurisdictions under the BIA in Alaska and Oklahoma). After unsuccessful administrative appeals, respondents instituted this purported class action, claiming, inter alia, entitlement to such general assistance as a matter of statutory interpretation. The District Court's summary judgment for petitioner was reversed by the Court of Appeals on the ground that the Manual's residency limitation was inconsistent with the broad language of the Snyder Act, that Congress intended general assistance benefits to be available to all Indians, including those in respondents' position, and that Congress' subsequent actions in appropriating funds for the BIA general assistance program did not serve to ratify the imposed limitation.

Issue:

Are general assistance benefits available only to those Indians living on reservations in the United States (or in areas regulated by the Bureau of Indian Affairs in Alaska and Oklahoma), and are they thus unavailable to Indians (outside Alaska and Oklahoma) living off, although near, a reservation?

Answer:

No.

Conclusion:

The Court held that the general assistance benefits to needy Indians under the Snyder Act could not be denied to Indians who lived in an Indian community near their native reservation, and who maintained close economic and social ties with the reservation and had not been assimilated into general society, notwithstanding the "on reservations" residency limitation in the Bureau's manual, and notwithstanding the Bureau's formal budget request statements referring to general assistance for needy Indians "on reservations," since (1) neither the Snyder Act nor the pertinent appropriations acts imposed any geographical limitation on the availability of benefits, (2) for many years, the Bureau, which had made exceptions to its residency limitation to certain groups of off-reservation Indians, had made continual representations to appropriations subcommittees that Indians living off but "near" reservations and not assimilated into general society were treated as living "on reservations," eligible for Bureau services, including general assistance benefits, (3) the "on reservations" limitation in the Bureau's manual was not validly imposed, since it had not been published in the Federal Register or in the Code of Federal Regulations, as required by the Administrative Procedure Act (5 USCS 552(a)(1)) and by the Bureau's own policies, and (4) even assuming that Congress was aware of the manual's residency limitation when appropriations were made, nevertheless there was no reason to assume that Congress did not equate the "on reservations" language with the "on or near" category which the Bureau had continuously described as its service area--the appropriations thus being intended to cover welfare services at least to those unassimilated Indians residing "on or near" reservations.

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