Does a notary have to be an US citizen?

Apparently the US Supreme Court decided that 27 years ago in Bernal. There the Court ruled Texas could not require a notary to be a citizen.

Nonetheless, the official notary web sites for 5 states still contain a US citizenship requirement:

Kansas
Missouri (see page 16)
Oklahoma
Rhode Island
South Carolina

Presumably a resident alien could sue and get a quick summary judgment allowing an application.

Still, it's been almost 30 years since the Supreme Court made its ruling!


Image courtesy of Salvatore Vuono