## Facts

- Ramon and Anita Ruiz, Papago (Tohono O’odham) Indians and U.S. citizens, left their reservation in 1940 and lived in an Indian community a few miles away, while maintaining close economic and social ties to the reservation.
- During a prolonged 1967 strike at a nearby mine, Ruiz applied to the Bureau of Indian Affairs (BIA) for general assistance benefits funded under the Snyder Act, 25 U.S.C. § 13.
- The BIA denied benefits based on a provision in its Indian Affairs Manual limiting general assistance eligibility to Indians living “on reservations” (and specified jurisdictions in Alaska and Oklahoma).
- The residency restriction was an internal manual policy that was not published in the Federal Register or codified in regulations.
- After unsuccessful administrative appeals, the Ruizes filed a putative class action in federal district court challenging the denial.
- The district court granted summary judgment for the Secretary of the Interior; the Ninth Circuit reversed, concluding the “on reservations” limitation conflicted with the Snyder Act and was not ratified by appropriations.

## Issues

1. Whether the Snyder Act permits the BIA to restrict general assistance benefits to Indians living “on reservations,” excluding Indians living in Indian communities near reservations with close ties to them.
2. Whether the BIA may enforce a substantive eligibility limitation contained only in an unpublished internal manual provision, without fair public notice or orderly administrative procedures.
3. Whether congressional appropriations made while the manual limitation existed implicitly ratified the “on reservations” restriction.

## Decision

- The Supreme Court affirmed the Ninth Circuit and remanded.
- The Court held Congress did not intend to exclude Indians like the Ruizes—unassimilated Indians living in Indian communities near their reservations and maintaining close ties—from Snyder Act general assistance.
- The Court held the BIA could not deny benefits based on the unpublished manual residency limitation, particularly where it was not fairly disclosed and was inconsistent with the statute’s purpose as Congress understood it.
- The Court rejected the claim that appropriations during the period the manual limitation existed amounted to congressional ratification, absent evidence the limitation was presented to and considered by Congress.

## Legal Principles

- Agency interpretations receive weight only to the extent they are consistent with congressional purpose.
- Distribution criteria for statutory benefit programs must be reasonably related to the enabling statute’s purposes and fairly disclosed; agencies may not deny benefits based on unpublished, internal eligibility rules.
- Appropriations measures generally do not effect substantive ratification of an agency’s restrictive policy without clear evidence Congress was aware of and accepted the specific limitation.

## Conclusion

The Court required the BIA to administer Snyder Act general assistance in line with Congress’s understanding that benefits reach eligible Indians “on or near” reservations, and it barred enforcement of a restrictive, unpublished manual rule as a basis for denying benefits.


Morton v. Ruiz, 415 U.S. 199 (1974)