For these purposes, it should be recalled that article 16 of the National Constitution guarantees equal protection of all residents and access to employment “with fitness being the only condition.” Additionally, article 20 of the Constitution recognizes that “Foreigners enjoy, on national territory, all the same civil rights as citizens; they can engage in industry, commerce, and professional work. They are not required to become citizens. It takes two consecutive years of residency to become a naturalized citizen in Argentina; however, authorities can shorten that time period if requested by those who claim and demonstrate having served the Republic.” (...) it observes that the Notary Association—which has been called on to contribute to this inquiry pursuant to the organic law on the notary profession (which requires its intervention, article 9)—invoked the letter of the law without arguing for substantial aims, unique to the exercise of the private notary practice, requiring that only natural-born citizens or citizens who had been naturalized for at least six years can do the work. Neither did it point to the reasons why the case law set by the Supreme Court (in response to similar circumstances) was not applicable. X. It should not be forgotten that the applicant was born in 1973 (see p. 7), in Spain. As suggested by the evidence attached to p. 21, she has been living in the country since 1982 (that is, since the age of 9). She attended primary school, secondary school, and university in Argentina (p. 22/31 and 13), and also passed the exam to become a notary. She married a citizen (p. 48) and has two daughters born in Argentina (p. 49). She owns at least one piece of property in Argentina (p. 50/2). She has pursued her work and professional life in Argentina for more than 22 years (p. 27/45). Her legal background as a citizen is documented on p. 14/15 (attested affidavit); 17 (certification that she does not owe alimony); and 20 (certification that she has no criminal record). XII. From the legal background described in the previous paragraph, it can be clearly concluded that none of the functions or competencies legally corresponding to notaries in the exercise of their liberal profession merits requiring citizenship of six years, for which reason, this requirement is in violation of articles 16 and 20 of the National Constitution, and therefore, not applicable with regard to the applicant in this proceeding. (…)XVIII. Therefore, it must be concluded that the requirements set forth in article 8, subparagraph a) of the aforementioned law (which constituted the only obstacle to registration in the Notaries Association) is not applicable to the petitioner because applying it by the letter would amount to discrimination (between natural born citizens, on one hand, and foreigners who meet the substantive requirements to be considered Argentines on the other) in violation of the constitutional principle of equal protection.34 65. Likewise, in the case of Bernal v. Fainter, the U.S. Supreme Court ruled a Texas statute requiring people to be U.S. resident citizens in order to be appointed notary publics unconstitutional, finding that it violated the equal protection clause of the 14th amendment. Although this decision does not specifically address a Latin notary system, certain of its considerations are relevant to this case. (...) As a general matter, a state law that discriminates on the basis of alienage can be sustained only if it can withstand strict judicial scrutiny. In order to withstand strict scrutiny, the law must advance a compelling state interest by the least restrictive means available. (...) Under this exception, the standard of review is lowered when evaluating the validity of exclusions that entrust only to citizens important elective and nonelective positions whose operations go to the heart of representative government (...). The statute provides that, “[t]o be eligible for appointment as a Notary Public, a person shall be a resident citizen of the United States and of this state (...) (...) The Court of Appeals ably articulated this argument: “With the power to acknowledge instruments such as wills and deeds and leases and mortgages; to take out-of-court depositions; to administer oaths; and the discretion to refuse to perform any of the foregoing acts, notaries public in Texas are involved in countless matters of importance to the day-to-day functioning of state government. The Texas political community depends upon the notary public to insure that those persons executing documents are accurately identified, to refuse to certify any identification that is false or uncertain, and to insist that oaths are properly and accurately administered. Land titles and property succession depend upon the care and integrity of the notary public, as well as the familiarity of the notary with the community, to verify the authenticity of the execution of the documents.” We recognize the critical need for a notary’s duties to be carried out correctly and with integrity. But a notary’s duties, important as they are, hardly implicate responsibilities that go to the heart of representative government. Rather, Judgment of the Appeals Chamber on Administrative and Tax Disputes of the Autonomous City of Buenos Aires, Martín and Mata Verónica, August 5, 2014. 34 13