The following excerpt is from Rivera v. Clinton Corr. Facility, No. 13-4394-pr (2nd Cir. 2015):
Whitmore v. Arkansas, 495 U.S. 149, 163-64 (1990) (citations omitted). "The burden is on the 'next friend' clearly to establish the propriety of [her] status and thereby justify the jurisdiction of the court." Id. at 164.
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