Morton v. Ruiz
United States Supreme Court
415 U.S. 199 (1974)
Ramon and Anita Ruiz (plaintiffs), Papago Indians and U.S. citizens who left their reservation to seek work in a nearby Arizona town, applied to the Bureau of Indian Affairs (BIA) for Snyder Act assistance benefits after a mine strike, but the BIA denied benefits solely because the Ruizes lived outside the reservation's boundaries, citing an unpublished internal manual policy limiting benefits to on-reservation Indians dating to 1952. The Ruizes filed a class action against the BIA Secretary (defendant), the district court granted the BIA summary judgment, and the court of appeals reversed, finding the residency requirement inconsistent with the Snyder Act.
Whether a federal agency may promulgate internal rules that limit how benefits are distributed which are not publicized and which are not accomplished by rulemaking procedures according to the Administrative Procedure Act.