25 C.F.R. § 700.69
Head of household
(a) Household. A household is:
(1) A group of two or more persons living together at a specific location who form a unit of permanent and domestic character.
(2) A single person who at the time his/her residence on land partitioned to the Tribe of which he/she is not a member actually maintained and supported him/herself or was legally married and is now legally divorced.
(b) Head of household. The head of household is that individual who speaks on behalf of the members of the household and who is designated by the household members to act as such.
(c) In order to qualify as a head of household, the individual must have been a head of household as of the time he/she moved from the land partitioned to a tribe of which they were not a member.
Notes of Decisions
Cited in 22
cases (16 in the last 5 years), 1990–2026 · leading case: Maine Ass'n of Interdependent Neighborhoods v. Comm'r, Maine Dep't of Human Servs., 732 F. Supp. 248 (D. Me. 1990).
Maine Ass'n of Interdependent Neighborhoods v. Comm'r, Maine Dep't of Human Servs., 732 F. Supp. 248 (D. Me. 1990). “1866 (a) (1988); 25 C.F.R. § 700.69 (b) (1988). 7 . Plaintiff relies on the following excerpts from the 1977 House Report: Congress did not want to "mak[e] it more difficult for a working household with an income at level $X to purchase its food stamps than a non-working…”
Manygoats v. Off. of Navajo & Hopi Indian Relocation, 735 F. Supp. 949 (D. Ariz. 1990). “25 C.F.R. § 700.69 (Supp.1989). Eligibility for the services provided under this Act and these regulations require that the head of household and/or the immediate family must have been residents on 12/22/74 of an area partitioned to the Tribe of which they were not members.”
Verna v. Coler, 893 F.2d 1238 (11th Cir. 1990). “” 25 C.F.R. § 700.69 (b) (1988). The use of the term “primary wage earner” clearly connotes a different concept from the term “head of household.”
Louise Ambrose v. Off. of Navajo & Hopi Indian Relocation (9th Cir. 2024). “” 25 C.F.R. § 700.69 (c), see id. §§ 700.69(a)(2), 700.”
Bruce Yazzie v. Off. of Navajo & Hopi Indian Relocation (9th Cir. 2024). “” 25 C.F.R. § 700.69 (a)(2) (emphasis added).”
Ambrose v. Off. of Navajo & Hopi Indian Relocation (D. Ariz. 2022). “” 25 C.F.R. §§ 700.69 (c) and 20 700.147(e).”
Yazzie v. Off. of Navajo & Hopi Indian Relocation (D. Ariz. 2024). “” 25 C.F.R. § 700.69 (b). A single person may also qualify as head of household if, 20 while living “on land partitioned to the Tribe of which he/she is not a member,” such person 21 “actually maintained and supported him/herself[.”
Bitah v. Off. of Navajo & Hopi Indian Relocation (D. Ariz. 2025). “See 25 C.F.R. §§ 700.69 (c), 9 700.147(e). So, under the Act, Plaintiff bears the burden of proving she was the “the head 10 of household” (“HoH”) on or before April 3, 1976.”
Ancita Tsosie v. Onhir (9th Cir. 2019). “25 C.F.R. § 700.69 (a)(2), (c). Setting these flawed justifications aside, Tsosie met her burden to demonstrate head-of-household status because she earned $1,300 per year or more by 1979.”
Rosita George v. Ofc. of Navajo & Hopi Indian (9th Cir. 2020). “ONHIR denied George’s application on the basis that she failed to show “head of 1 Pursuant to 25 C.F.R. § 700.69 (c), a Navajo applicant must establish she was the head of household at the time she was forced to relocate.”
Justin Begay v. Off. of Navajo & Hopi Indian Relocation (9th Cir. 2023). “See 25 C.F.R. § 700.69 ; § 700.147. Begay filed suit in the district court and the district court granted summary judgment affirming ONHIR’s decision.”
Leland Todicheeney v. Off. of Navajo & Hopi Indian Relocation (9th Cir. 2024). “” 25 C.F.R. § 700.69 (a)(2) (emphasis added).”
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