AnalysisIn light of the 1984 Bernal v. Fainter U.S. Supreme Court decision, which established that U.S. citizenship could not be a qualification for a Notary Public commission, and the current immigration debate, Arizona has amended its statute with a provision clarifying that an applicant for a Notary commission must permanently and legally reside in Arizona if he or she is not a citizen of the U.S.
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