In Buttany v. Barrackas, 2019 U.S. Dist. LEXIS 190261, *5-6 (E.D. Cal., Nov. 1, 2019), the court concluded that a mother suing on behalf of her minor children, beneficiaries of an I-864, could not assert a breach of contract claim pursuant to the I-864, pro se. (“To the extent that plaintiff may be attempting to set forth a claim for breach of an affidavit of support pursuant to 8 C.F.R. § 213a.2, plaintiff cannot do so as a pro se plaintiff on behalf of minor children.”). This result is somewhat surprising, as parents may often bring claims as a “next friend” for their minor children. It is a good idea not to reach much into the case holding, however, as the litigant was pro se and the Court likely had little briefing before it.