REPORT No. 194/20
CASE 12,730


1. On November 5, 2004, the Inter-American Commission on Human Rights (hereinafter “the Inter-American
Commission,” the “Commission,” or the “IACHR”) received a petition submitted by Steven Edward Hendrix
(hereinafter “the petitioner”) alleging the Republic of Guatemala (hereinafter the “Guatemalan State,” the
“State” or “Guatemala”) was internationally responsible for the violation of a series of rights enshrined in the
American Convention on Human Rights (hereinafter the “Convention” or the “American Convention”) as a
consequence of administrative decisions and a judicial decision preventing him from exercising the profession
of notary despite having the corresponding university degree obtained in Guatemala on the grounds that he
was not a Guatemalan citizen.
2. The Commission approved admissibility report 101/09 on October 29, 2009.1 On November 20, 2009, the
Commission notified the parties of the report and made itself available to help them reach a friendly
settlement, but the conditions were not met for resolving the case through that process. The parties were
given the time provided for in the Rules of Procedure to submit additional comments on the merits. All the
information received was duly transferred between the parties.
A. Petitioner:
3. The petitioner stated that he was a U.S. citizen and received the degree of Juris Doctorate from the
University of Wisconsin, United States, in 1987, as well as the degrees of Doctor of Laws and Lawyer of the
Universidad Mayor de San Andrés, Bolivia. He stated that he did his doctoral work and studied law and the
notary profession at the Universidad de San Carlos de Guatemala (USAC), and said that after taking the
corresponding exams, on September 18, 2000, the Board of the School of Law of the USAC of Guatemala
granted him the titles of “Attorney and Notary.”
4. He stated that on November 22, 2000, he filed a request to register as an attorney and notary with the
Association of Lawyers and Notaries of Guatemala. However, on February 6, 2001, its governing board
resolved only to register him and swear him in as a lawyer, as domestic legislation establishes that all notaries
must be Guatemalan by birth.
5. He stated that he appealed this decision to the Assembly of Presidents of the Professional Associations of
Guatemala, which denied his appeal on April 22, 2002. In response to this, he filed a writ of amparo before the
Third Chamber of the Court of Appeals, which denied it on June 25, 2002, finding there was no evidence of any
of the alleged violations.
6. He stated that lastly, he filed a writ of amparo against this resolution before the Constitutional Court,
which, on April 21, 2004, denied it. However, it found he could register as a notary if he underwent the
naturalization process to become a Guatemalan citizen. He argued that the State could not require him to


Report No. 101/09. Petition 1184-04. Steven Edward Hendrix. Guatemala. October 29, 2009 In that report, the IACHR found the
petition admissible with regard to the alleged violation of Article 24, in conjunction with articles 1(1) and 2 of the American Convention.
In the report, the IACHR also found the petition inadmissible with respect to the alleged violation of Articles 20 and 26 of the American

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