The Ninth Circuit Court of Appeals reversed a district court ruling Monday and remanded the case of *Yazzie v. United States Office of Navajo and Hopi Indian Relocation*, finding in favor of a Navajo man who challenged the denial of relocation benefits under federal law.
Harvey Yazzie brought suit under the Administrative Procedure Act seeking judicial review of a decision by the Office of Navajo and Hopi Indian Relocation that determined he was not eligible for relocation benefits under the Navajo Hopi Land Settlement Act of 1974. The U.S. District Court for the District of Arizona had granted summary judgment to ONHIR, but the appeals court disagreed.
The case stems from the decades-long legal and administrative process following passage of the Navajo Hopi Land Settlement Act of 1974, landmark federal legislation that addressed land disputes between the Navajo and Hopi tribes in Arizona. The act established procedures for determining land ownership and provided for relocation assistance to families required to move from disputed territories.
Under the Settlement Act, eligible individuals can receive various forms of relocation assistance, including housing, moving expenses, and other benefits designed to help families transition from lands they were required to vacate. The Office of Navajo and Hopi Indian Relocation was created specifically to administer these benefits and oversee the relocation process.
Yazzie's case was argued and submitted before Circuit Judges Collins, Mendoza, and Desai on Sept. 15, 2025, in Phoenix. The three-judge panel reviewed the lower court's decision using the de novo standard of review, meaning they examined the case fresh without deferring to the district court's findings.
In applying Administrative Procedure Act standards to ONHIR's decision, the appeals court examined whether the agency's determination was "arbitrary, capricious, an abuse of discretion, not in accordance with law, or unsupported by substantial evidence," according to the opinion. This represents the standard framework federal courts use when reviewing administrative agency decisions under APA guidelines.
The Ninth Circuit cited its own precedent in *Bedoni v. Navajo-Hopi Indian Relocation Commission* from 1989, demonstrating the long history of litigation surrounding the implementation of the Settlement Act. The court also referenced the more recent case *Barton v. Office of Navajo and Hopi Indian Relocation* from 2025, showing that disputes over relocation benefits continue to reach federal courts decades after the original legislation.
District Judge James A. Teilborg had presided over the case in the lower court, where ONHIR successfully argued that Yazzie was not entitled to relocation benefits under the Settlement Act. The specific grounds for ONHIR's denial and the district court's reasoning were not detailed in the available portion of the appeals court's memorandum.
The reversal represents a victory for Yazzie and potentially affects how ONHIR evaluates eligibility for relocation benefits under the 1974 act. The case will now return to the district court for further proceedings consistent with the appeals court's ruling.
The Navajo Hopi Land Settlement Act has generated extensive litigation since its enactment more than 50 years ago. The legislation was Congress's attempt to resolve a complex land dispute that had persisted for generations between the two tribes in northeastern Arizona. The act partitioned disputed lands and required thousands of Navajo families to relocate from areas awarded to the Hopi Tribe.
The relocation process has been marked by controversy and legal challenges, with many Navajo families arguing they were unfairly displaced from ancestral lands. The Office of Navajo and Hopi Indian Relocation has faced numerous lawsuits over the years from individuals seeking benefits or challenging the agency's implementation of the Settlement Act.
The appeals court's decision was issued as a memorandum marked "not for publication," meaning it does not establish binding precedent beyond the specific case. However, the ruling provides guidance on how courts should review ONHIR decisions under APA standards.
The case highlights ongoing issues with federal administration of tribal relocation programs and the continuing legal ramifications of the 1974 Settlement Act. For Yazzie, the reversal means his case will receive fresh consideration at the district court level.
The ruling also underscores the important role federal appeals courts play in reviewing administrative decisions affecting Native American communities. The Ninth Circuit has jurisdiction over several states with significant tribal populations and regularly handles cases involving federal Indian law and tribal rights.
With the case remanded to the district court, Yazzie will have another opportunity to pursue his claim for relocation benefits under the Settlement Act. The specific instructions from the appeals court for how the lower court should proceed on remand were not included in the available excerpt of the opinion.