Morton v. Ruiz
Encyclopedia
Morton v. Ruiz, 415 U.S.199
(1974), was a case heard before the United States Supreme Court
.
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. The Supreme Court in an opinion written by Justice Blackmun
held that these 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."
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1974), was a case heard before the United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
.
Ramon Ruiz and his wife Anita were Papago
Papago
Papago may refer to:* An archaic term for Tohono O'odham people* Papago , a genus of geometer moths* Papago Freeway, I-10 through Phoenix, Arizona* Papago Freeway Tunnel, a tunnel in Arizona* Papago Park, a park in Arizona...
Indians and U.S. citizens who in 1940 left the Papago reservation
Indian reservation
An American Indian reservation is an area of land managed by a Native American tribe under the United States Department of the Interior's Bureau of Indian Affairs...
in Arizona
Arizona
Arizona ; is a state located in the southwestern region of the United States. It is also part of the western United States and the mountain west. The capital and largest city is Phoenix...
to seek employment 15 miles away at the Phelps-Dodge copper mines at Ajo
Ajo, Arizona
Ajo is a census-designated place in Pima County, Arizona, United States. The population was 3,705 at the 2000 census. Ajo is located on State Route 85 just from the Mexican border. It is the closest community to Organ Pipe Cactus National Monument....
. 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
Bureau of Indian Affairs
The Bureau of Indian Affairs is an agency of the federal government of the United States within the US Department of the Interior. It is responsible for the administration and management of of land held in trust by the United States for Native Americans in the United States, Native American...
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
Alaska
Alaska is the largest state in the United States by area. It is situated in the northwest extremity of the North American continent, with Canada to the east, the Arctic Ocean to the north, and the Pacific Ocean to the west and south, with Russia further west across the Bering Strait...
and Oklahoma
Oklahoma
Oklahoma is a state located in the South Central region of the United States of America. With an estimated 3,751,351 residents as of the 2010 census and a land area of 68,667 square miles , Oklahoma is the 28th most populous and 20th-largest state...
. The legislation authorizing payment of benefits by the BIA had no express residential criteria.
This policy had not been published in the Federal Register
Federal Register
The Federal Register , abbreviated FR, or sometimes Fed. Reg.) is the official journal of the federal government of the United States that contains most routine publications and public notices of government agencies...
or in the Code of Federal Regulations
Code of Federal Regulations
The Code of Federal Regulations is the codification of the general and permanent rules and regulations published in the Federal Register by the executive departments and agencies of the Federal Government of the United States.The CFR is published by the Office of the Federal Register, an agency...
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
Bureau of Indian Affairs
The Bureau of Indian Affairs is an agency of the federal government of the United States within the US Department of the Interior. It is responsible for the administration and management of of land held in trust by the United States for Native Americans in the United States, Native American...
was not required to follow the Administrative Procedures Act Section 553 for benefit disbursement, they expressed internal policies that they would follow it. The Supreme Court in an opinion written by Justice Blackmun
Harry Blackmun
Harold Andrew Blackmun was an Associate Justice of the Supreme Court of the United States from 1970 until 1994. He is best known as the author of Roe v. Wade.- Early years and professional career :...
held that these 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."