Morton v. Ruiz

Supreme Court of the United States · 1974 · Administrative Law

Administrative LawAgency RulemakingPublication RequirementsIndian AffairsAdministrative Procedure ActFederal Registeragency procedureunpublished rules

Facts

Ramon and Anita Ruiz were Papago Indians who had lived since 1940 in an Indian community at Ajo, about 15 miles from the Papago Reservation, while maintaining close economic and social ties to the reservation and remaining unassimilated. During a mine strike in 1967, Ruiz sought BIA general assistance after state welfare was denied. The BIA denied benefits solely because the family lived outside the reservation boundaries, relying on an Indian Affairs Manual provision limiting eligibility to Indians living "on reservations" except in Alaska and Oklahoma. The BIA had not published this eligibility restriction in the Federal Register or Code of Federal Regulations.

Issue

May the BIA deny general assistance to otherwise eligible Indians living near, but not within, a reservation based on an unpublished Manual provision limiting benefits to those living "on reservations"? More specifically, was that restriction validly imposed consistently with congressional intent and required administrative procedures?

Rule

An agency administering a congressionally funded program may make reasonable classifications to allocate limited funds, but if it adopts a substantive eligibility standard affecting individual rights, it must make that standard generally known and follow its own procedures and the APA's publication requirements. An unpublished internal rule cannot effectively extinguish benefits of persons otherwise within the class of beneficiaries contemplated by Congress.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

The Federal Coastal Assistance Office administers a congressional program that provides emergency cash aid to fishing families. The statute and appropriations language contain no geographic cutoff, but the agency denies Lena Ortiz's application in Corpus Christi because an internal staff handbook limits aid to families living within municipal harbor districts. That handbook was never published in the Federal Register or CFR, and Lena otherwise satisfies all stated criteria.

Is the denial most likely valid?

Explanation. The majority held that even if an agency may adopt reasonable classifications to allocate limited funds, it must make a substantive eligibility standard generally known and comply with applicable publication procedures before using it to deny benefits. An internal handbook or manual provision cannot effectively extinguish benefits of persons otherwise within the class Congress contemplated. The defect is procedural and administrative, not dependent on a constitutional showing.