which states that Colombia has an obligation to resolve the nationality status of its residents, in this case by affirmatively investigating or facilitating access to competent authorities in Peru to ensure nationality or provide naturalization to this lifelong resident of Colombia. In 2010, the Constitutional Court heard a similar case. The applicant was also born in the Amazonas state to Peruvian parents. The Civil Registry Office had granted her both a birth certificate and a national identity card, but denied her a citizenship card.334 The court cited the 2008 judgment in rendering its decision, finding that the National Civil Registry Office in Leticia had erred in granting her a national identity card.335 It ordered the Civil Registry to instruct its officers in border regions to verify the proof of domicile—at that time through a resident’s visa—for children born to foreign parents before granting documentation to avoid giving individuals false perceptions of their rights.336 In 2015,337 the Constitutional Court decided the case of a child born in Colombia to Chinese parents, one of whom had a nonresident work visa at the time of the child’s birth. They had received a birth certificate listing the child’s nationality as Colombian but the local passport office, under the jurisdiction of the Ministry of Foreign Affairs, had denied the child a passport.338 The local passports office claimed the child was not entitled to a Colombian passport because neither of the parents had proven domicile. The court considered that this legal provision was contrary to what the Ministry of Foreign Affairs had established in its administrative orders S-GAUC-14-093078 (December 16, 2014) and S-GAUC-14-095488 (December 29, 2014) in which it extended the means that served as proof of domicile to include a non-resident work visa. It ordered the ministry to implement a nationwide policy with concrete mechanisms of disseminating the new interpretation of this requirement for the issuance of passports. Thus, while the most recent case law provides some cause for optimism, a broader view shows the case law to be uneven at best. Such inconsistency is especially hard on populations at risk of statelessness, as examined in the next section. Populations at Risk of Statelessness Internally displaced persons, refugees, and migrants are the primary populations at risk of stateless in Colombia. Research conducted for this report identified the complex steps required to obtain documents, such as notarization and apostilles, as a significant barrier for members of these groups. As the case studies in this chapter suggest, children entitled to Colombian nationality have been denied it because of these formalities. Similarly, children who would be entitled to nationality under an absolute jus soli prin- 76 COUNTRY PROFILES l COLOMBIA