by ... his. brother-in-law. It is proper practice to make an application by one on behalf of another.... An application may be made by a parent or guardian having a superior right to the custody and control of the person illegally detained, when such person might not himself obtain relief. Ex parte Dostal, 243 F. 664, 668 (N.D.Ohio 1917). The Second Circuit Court of Appeals further elaborated upon the practice and its limitations in 1921: It has never been understood that, at common law, authority from a person unlawfully imprisoned or deprived of his liberty was necessary to warrant the issuing of a habeas corpus, to inquire into the cause of his detention.... But the complaint must set forth some reason or explanation satisfactory 59 L.Ed.2d 756 (1979) (Rehnquist, Circuit Justice) (<HOLDING>); Hamilton v. Texas, 485 U.S. 1042, 1042, 108
recognizing distinction between corporate officer acting on behalf of himself and corporate officer acting on behalf of his corporation recognizing for purposes of stay nextfriend standing of mother on behalf of prisoner holding that claim belongs to child but allowing mother to assert it on childs behalf holding that the minor was otherwise represented because the childs legal guardian his mother brought the action on his behalf recognizing that prisoners former attorney had a significant relationship with the prisoner for purposes of next friend standing because attorney had acted on behalf of the prisoner in prior legal proceedings