Bernal v. Fainter, 467 U.S. 216 (1984), is a case in which the Supreme Court of the United States ruled that the Equal Protection Clause prohibited the state of Texas from barring noncitizens from applying for commission as a notary public.

[4] The trial court ruled in favor of the applicant and found that under the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution, Texas' citizenship requirement did not pass either strict scrutiny or rational basis review.

[8] The Court also recognized a "political function" exception that subjects alienage classification laws to a lower standard of review for "positions intimately related to the process of democratic self-governance.

[10] The Court noted that this is unlike the role played by other individuals in who work in judicial systems, such as judges or police officer, where a locality may require police officers to be citizens because they act on behalf of the state and have considerable discretion in how the law is enforced.

[11] Consequently, the Supreme Court struck down the Texas law that required a notary to be a citizen.