Morton v. Ruiz
Citations
- 415 U.S. 199
- 94 S. Ct. 1055
- 39 L. Ed. 2d 270
- 1974 U.S. LEXIS 99
About this case
From Wikipedia, the free encyclopedia
1974 US Supreme Court case involving the Bureau of Indian Affairs
1974 United States Supreme Court case
Morton v. Ruiz, 415 U.S. 199 (1974), was a case heard before the United States Supreme Court affirming the right of Native Americans living on reservations to receive state assistance.
Background
[(https://en.wikipedia.org/w/index.php?title=Morton_v._Ruiz&action=edit§ion=1 "Edit section: Background")
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Ramon Ruiz and his wife Anita were Papago Indians and U.S. citizens who in 1940 left the Papago reservation in Arizona to seek employment 15 miles away at the Phelps-Dodge copper mines at Ajo . They settled in a community called the "Indian Village" and maintained close ties with the nearby reservation.
On December 11, 1967, Mr. Ruiz applied for general assistance benefits from the Bureau of Indian Affairs and was immediately notified by letter that he was ineligible for general benefits because of a provision in 66 Indian Affairs Manual 3.1.4 (1965) that eligibility was limited to Indians living "on reservations" and certain jurisdictions in Alaska and Oklahoma . The legislation authorizing payment of benefits by the BIA had no express residential criteria.
This policy had not been published in the Federal Register or in the Code of Federal Regulations and its only manifestation was solely an internal-operations brochure at the Bureau of Indian Affairs intended to cover policies that "do not relate to the public." Even though the Bureau of Indian Affairs was not required to follow the Administrative Procedures Act Section 553 for benefit disbursement, they expressed internal policies that they would follow it.
Arguments and ruling
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Ruiz pursued the class action lawsuit, "entitlement to such general assistance as a matter of statutory interpretation".
The Supreme Court, in an opinion written by Justice Blackmun , held that the internal Section 553 procedures were not followed, and thus benefits could not be limited.
The Supreme Court further said, "[In] order for an agency interpretation to be granted deference, it must be consistent with the congressional purpose. It is evident to us that Congress did not itself intend to limit its authorization to only those Indians directly on, in contrast to those 'near,' the reservation, and that, therefore, the BIA's interpretation must fail."
External links
[(https://en.wikipedia.org/w/index.php?title=Morton_v._Ruiz&action=edit§ion=3 "Edit section: External links")
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- Text of Morton v. Ruiz, 415 U.S. 199 (1974) is available from: CourtListener Findlaw Google Scholar Internet Archive (docket files) Justia Library of Congress Oyez (oral argument audio)
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How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- holding that a substantive rule or “a legislative-type rule,” is one that “affect[s] individual rights and obligations.”
- holding that the Bureau of Indian Affairs’s unpublicized eligibility criteria restricting apportionment of funds that would limit the ability of Native Americans to receive federal benefits affected their substantial individual rights
- holding that the Bureau of Indian Affairs's unpublicized eligibility criteria restricting apportionment of funds that would limit the ability of Native Americans to receive federal benefits affected their substantial individual rights
- holding Bureau of Indian Affairs had to follow procedures set forth in its internal policy manual
- holding that “[w]here the rights of individuals are affected, it is incumbent upon agencies to follow their own procedures. This is so even where the internal 13 procedures are possibly more rigorous than otherwise would be required.”
- holding Government violation of regulations consistent with treatment of pretrial prisoners as innocent amounted to an abuse of discretion under R.C.M. 305(k)
Source: CourtListener parenthetical corpus (CC0).
Judges: Blackmun
Read full opinion on CourtListenerSourced from CourtListener / Free Law Project (CC0).
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.