Bernal v. Fainter

Bernal (plaintiff), a Mexican-born resident alien who had lived in the U.S. for 17 years, applied to become a notary public in Texas. The Texas Secretary of State (defendant) denied him under a statute requiring notaries to be U.S. citizens. After an unsuccessful administrative appeal, Bernal sued in federal court, arguing the citizenship requirement violated equal protection. The district court agreed, applying strict scrutiny, but the court of appeals reversed, holding only rational-basis review applied and that the requirement was rationally related to the orderly handling of legal documents.