Estonia has 1.36 million residents. About 84 percent are Estonian or EU citizens, while 16 percent are third-country nationals or stateless persons.

Of the latter, more than half — around 130,000 — are Russian citizens or stateless persons, also known as "gray passport holders," many of whom remained in the country after the collapse of the Soviet Union.

Another 90,000 come from other countries, including about 7,500 permanent residents.

Among them are American Stewart Johnson and Ecuadorian Jorge Hinojosa, who have lived in Estonia for nearly three decades. Both are well integrated into Estonian society, with families and careers here, but neither can obtain Estonian citizenship due to legal conflicts between Estonia and their home countries.

ETV's "Pealtnägija" spoke to several foreigners in similar situations. Like Johnson and Hinojosa, many arrived for personal reasons and have since put down roots, though some declined to appear on camera, fearing judgment despite considering themselves loyal to Estonia.

Textbook example of integration

Hinojosa moved to Estonia in January 1999 after meeting his future wife Ingrid in the United States two years earlier. When he learned she was pregnant, the ex-mountaineer sold his gear and relocated from Ecuador, population 16 million, to a tiny Northern European country he barely knew.

Hinojosa recalled being puzzled by the smoked sprat sandwich he was offered on his Estonian Air flight from Frankfurt. "And then I landed in Estonia and it was very cold and dark", he said.

Ingrid Hinojosa said he began learning Estonian right away using a phrasebook and a cassette by L'Dorado, a local Latin music band that performed in Estonian, which he kept on heavy rotation.

Over 27 years living in Estonia, Jorge Hinojosa has worked as a tour guide, travel organizer and dance instructor, becoming a familiar figure in his community and appearing more than once in the Estonian news. A staunch sauna convert, he has joined his wife competing in sauna marathons, and the couple has even performed together in a folk dance troupe.

Their younger son is currently an active student in high school, while their older son teaches at the Estonian Academy of Arts (EKA), with a special interest in improving Tallinn's urban landscape.

'I don't want to be part of the U.S. anymore'

Johnson, a stand-up comedian and writer, has lived in Estonia for 28 years. His children were born here, and in nearly three decades, he has returned to the U.S. only a handful of times.

"The last time [I visited] was nearly seven years ago, when my mother died; I was there for a week," he recalled. "Before that, it was 15 years ago. Also for a week."

Given recent political developments, Johnson said he would be willing to give up his U.S. citizenship. He also questioned what might happen to him as an American citizen if Estonia, as part of NATO, were ever to end up at war with the U.S.

"I don't want to be part of that country anymore," he said, criticizing the current administration, while noting that many people there also hate what is happening.

Both men face the same obstacle. People born citizens of Estonia, whether as dual citizens or naturalizing elsewhere, are protected by a loophole rooted in the Estonian Constitution.

Those seeking Estonian citizenship through naturalization, however, must pass language and civics exams and renounce any existing citizenships.

Some countries do not allow their citizens to renounce citizenship, creating a legal deadlock. Ecuador is one of them.

Ministry: Not our problem

"We understand that country indeed does not release its citizens from citizenship, but that does not change Estonian law," said Janek Mägi, head of the Interior Ministry's Border Guard and Migration Policy Department.

Under the Citizenship Act, Estonia does not allow multiple citizenships, largely for historical reasons. While dual Estonian-Russian citizens already exist, allowing it through naturalization could result in as many as 100,000 such citizens — nearly a tenth of the population.

Estonia does not track how many residents are affected by such conflicts with other countries' laws, and authorities say it is not their responsibility.

"At this time, that is of no importance to us whatsoever," Mägi said. "When granting or revoking citizenship, we follow Estonian law."

"Estonia cannot compel another country to release one of its citizens from their citizenship," added MP Ando Kiviberg (Eesti 200), chair of the Riigikogu's Constitutional Committee.

Despite passing the required language and civics exams, Hinojosa has repeatedly been blocked from completing the naturalization process.

Johnson, meanwhile, described a catch-22: the U.S. requires proof of another citizenship before allowing renunciation, while Estonia requires renunciation first. And the U.S. is just one of many such countries.

If there were some kind of agreement confirming the conditional naturalization decision in advance, Johnson added, "the rest would just be a matter of bureaucracy."

Officials say around 800 to 1,000 people are naturalized as Estonian citizens each year, many conditionally. In such cases, their Estonian citizenship takes effect only after proof of renunciation of their other citizenships is provided.

More than just a legal issue

For Hinojosa, the issue is more than just legal. As a third-country national, he has been denied bank loans and faces visa requirements and other hurdles the rest of his family doesn't when traveling, complicating something as basic as planning family vacations.

Despite being active in his local community in Saku Municipality and even encouraged by others to run for local office, his hands were tied when the Riigikogu voted last year to disenfranchise third-country nationals with a constitutional amendment.

On one hand, concerns over Estonia's demographic decline are growing louder. On the other, well-integrated foreigners, even those with children who are Estonian citizens, continue to face obstacles in obtaining citizenship themselves.

For families like the Hinojosas, the irony is stark: their sons, locally born and raised Estonian citizens, will be required to serve conscription in the Estonian Defense Forces (EDF) and, if called, fulfill their duty to defend the country.

Ingrid Hinojosa said the disparity her family faces leaves her deeply emotional as a mother.

"If their father isn't granted Estonian citizenship and isn't recognized as an Estonian citizen, why should my sons go and lay their lives on the line for a country like that?" she asked.

MP sees solution in Spain

Under the Citizenship Act, Estonia currently allows dual citizenship only in limited cases, such as for individuals directly facing persecution on a personal level. Officials maintain, however, that any broader change would require other countries to adjust their laws, not Estonia.

In a written response to the Hinojosa family, Kiviberg said Jorge Hinojosa's lack of citizenship does not make him any less a member of Estonian society.

Speaking to "Pealtnägija," the Constitutional Committee chair suggested Hinojosa could seek citizenship elsewhere, such as in Spain, an EU member state where dual citizenship may be allowed. He nonetheless urged Hinojosa to continue living in Estonia.

The family found the idea offensive and say they have even considered leaving as a result.

"It would be a painful loss," Kiviberg acknowledged, "But we'd just have to accept it. We cannot compromise our country's core principles, enshrined in the Constitution, to allow such exceptions."

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