Hmm, that is an interesting observation. My first reaction was yes, a record fish for a state should be from public accessible waters.
Technically a guy could set up a small pond in his backyard, order a few Florida strain female bass and raise them in a controlled environment. Then one day go out and catch one and have it certified.
But my second thought was how about a lake surrounded by private property with no public access, but there are several parcels of private land. In other words, someone does not “own” the lake by virtue of being accessible by several property owners? That one has me thinking.