The Petitioner, a non-U.S. citizen, worked as a paralegal, assisting migrant farmers in legal and employment matters in Texas. He applied for a notary public but was rejected based on a Texas state law which required notary publics to be United States citizens. The District Court held in favor of the Petitioner. The Circuit Court reversed and upheld the statute under a rational basis standard of review. The U.S. Supreme Court reversed and remanded.

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