Bernal (plaintiff) was a native of Mexico and a resident alien who had lived in the United States for 17 years. Bernal worked for a legal-aid organization and applied to the Texas Secretary of State (defendant) to become a notary public. Bernal’s application was denied pursuant to a Texas statute that required a notary public to be a United States citizen. Bernal appealed the decision through an administrative appeal process. After his administrative appeal was denied, Bernal filed an action in federal district court to challenge the constitutionality of the statutory citizenship requirement. The district court analyzed the statute under the strict-scrutiny standard and found that the citizenship requirement violated the Equal Protection Clause. The court of appeals reversed, holding that the appropriate standard of review was the rational-relationship test and finding that the statute bore a rational relationship to the state's interest in the orderly handling of legal documents that were important to the state. The United States Supreme Court granted certiorari.