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AZ DOC v. FCC, DC, Joint Intervenors Brief, Interstate ICS Rates, 2014

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USCA Case #13-1300

Document #1494161

Filed: 05/22/2014

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[ORAL ARGUMENT NOT YET SCHEDULED]
Nos. 13-1280, 13-1281, 13-1291, 13-1300, 14-1006
UNITED STATES COURT OF APPEALS
FOR THE DISTRICT OF COLUMBIA CIRCUIT
ARIZONA DEPARTMENT OF CORRECTIONS, MISSISSIPPI DEPARTMENT OF
CORRECTIONS, AND SOUTH DAKOTA DEPARTMENT OF CORRECTIONS,
Petitioners,
ARKANSAS DEPARTMENT OF CORRECTION, INDIANA DEPARTMENT OF CORRECTION,
AND BARNSTABLE COUNTY SHERIFF’S OFFICE,
Intervenors,
v.
FEDERAL COMMUNICATIONS COMMISSION AND THE UNITED STATES OF AMERICA,
Respondents.
On Petition For Review From A Final Order
Of The Federal Communications Commission
JOINT BRIEF FOR CORRECTIONAL FACILITY PETITIONERS
AND SUPPORTING INTERVENORS
Fred William Stork, III
Assistant Attorney General
OFFICE OF THE
ARIZONA ATTORNEY GENERAL
1275 West Washington
Phoenix, AZ 85007
(602) 542-8350
Fred.Stork@azag.gov

Helgi C. Walker
Counsel of Record
Scott G. Stewart
Philip S. Alito
GIBSON, DUNN & CRUTCHER LLP
1050 Connecticut Avenue, N.W.
Washington, D.C. 20036
(202) 887-3599
(202) 530-9595 (fax)
HWalker@gibsondunn.com

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C. Joseph Cordi, Jr.
Senior Assistant Attorney General
323 Center Street
Suite 200
Little Rock, AR 72201
(501) 682-1317
joe.cordi@arkansasag.gov
Matthew J. Murphy
General Counsel
BARNSTABLE COUNTY
SHERIFF’S OFFICE
600 Sheriff’s Place
Bourne, MA 02532
(508) 563-4311
mmurphy@bsheriff.net

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Timothy J. Junk
Jefferson S. Garn
Deputy Attorneys General
OFFICE OF THE ATTORNEY GENERAL
302 West Washington Street
Indianapolis, IN 46204
(317) 232-6247
tim.junk@atg.in.gov

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CERTIFICATE AS TO PARTIES, RULINGS, AND RELATED CASES
Pursuant to D.C. Circuit Rule 28(a)(1), petitioners Arizona Department of
Corrections, Mississippi Department of Corrections, and South Dakota Department
of Corrections, and supporting intervenors Arkansas Department of Correction,
Indiana Department of Correction, and Barnstable County Sheriff’s Office, certify
as follows:
A.

Parties And Intervenors
1.

Parties Before This Court

Petitioners in these consolidated cases are the Arizona Department of
Corrections (No. 14-1006); the Mississippi Department of Corrections and South
Dakota Department of Corrections (No. 13-1300); Securus Technologies, Inc. (No.
13-1280); Global Tel*Link Corp. (No. 13-1281); and CenturyLink Public
Communications, Inc. (No. 13-1291).
Respondents in these consolidated cases are the Federal Communications
Commission (“FCC” or “Commission”) and the United States of America.
The intervenors supporting petitioners in these consolidated cases are the
Arkansas Department of Correction, the Indiana Department of Correction, the
Barnstable County Sheriff’s Office, and Telmate, LLC.
The intervenors supporting respondents in these consolidated cases are Peter
Bliss, Winston Bliss, Ulandis Forte, Gaffney & Schember, Katharine Goray, David

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Hernandez, Lisa Hernandez, M. Elizabeth Kent, Jackie Lucas, Mattie Lucas,
Darrell Nelson, Laurie Nelson, Vendella F. Oura, Earl J. Peoples, Ethel Peoples,
Melvin Taylor, Sheila Taylor, Annette Wade, Charles Wade, Dorothy Wade, and
Martha Wright.
2.

Parties To The Proceeding Below

The parties that participated in the agency proceeding below—Rates for
Interstate Inmate Calling Services, WC Docket No. 12-375—are listed in
Appendix B of the order under review.
B.

Ruling Under Review

The order under review is the Commission’s Report and Order and Further
Notice of Proposed Rulemaking, Rates for Interstate Inmate Calling Services, FCC
13-113, 28 FCC Rcd 14107, 78 Fed. Reg. 67,956 (Nov. 13, 2013) (“Order”)
(JA__).
C.

Related Cases

The Order has not previously been the subject of a petition for review by
this Court or any other court. Petitioners are unaware of any related cases pending
before this Court or any other court.

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CORPORATE DISCLOSURE STATEMENT
Pursuant to D.C. Circuit Rule 26.1 and Federal Rule of Appellate Procedure
26.1, petitioners Arizona Department of Corrections, Mississippi Department of
Corrections, and South Dakota Department of Corrections, and supporting
intervenors Arkansas Department of Correction, Indiana Department of Correction,
and Barnstable County Sheriff’s Office, submit the following disclosure statement:
Petitioners and their supporting intervenors are governmental entities and
not subsidiaries of any parent corporation.
Respectfully submitted,
/s/ Helgi C. Walker
Helgi C. Walker
Counsel of Record
Scott G. Stewart
Philip S. Alito
GIBSON, DUNN & CRUTCHER LLP
1050 Connecticut Avenue, N.W.
Washington, D.C. 20036
(202) 887-3599
(202) 530-9595 (fax)
HWalker@gibsondunn.com
May 22, 2014

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TABLE OF CONTENTS
Page
TABLE OF AUTHORITIES ....................................................................................vi
GLOSSARY............................................................................................................... x
INTRODUCTION ..................................................................................................... 1
STATEMENT OF JURISDICTION.......................................................................... 5
STATEMENT OF THE ISSUES............................................................................... 5
STATUTES AND REGULATIONS ......................................................................... 6
STATEMENT OF THE CASE .................................................................................. 6
A.

Inmate Calling Services Require States And Localities To
Deploy Sophisticated Security Measures In Order To Keep The
Public Safe. ............................................................................................ 6

B.

In Accordance With Their Authority To Administer
Correctional Facilities, Many States And Localities Require
Inmate Calling Service Providers To Pay Site Commissions In
Order To Fund Correctional Budgets. ................................................... 9

C.

The Order Displaces The Judgments Of States And Localities
Regarding Sound Prison Management. ............................................... 12

D.

This Court Stays Key Elements Of The Order. .................................. 15

STANDARD OF REVIEW ..................................................................................... 15
SUMMARY OF ARGUMENT ............................................................................... 17
STATEMENT OF STANDING .............................................................................. 20
ARGUMENT ........................................................................................................... 21

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TABLE
OF CONTENTS

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(continued)
Page
I.

II.

III.

The Order Exceeds The Commission’s Authority By Intruding On
The Prerogatives Of State And Local Authorities......................................... 22
A.

State And Local Authorities—Not The Commission—Are
Entrusted With Administering Their Own Correctional
Facilities. ............................................................................................. 22

B.

The Order Intrudes On The Prerogatives Of State And Local
Authorities By Substituting The Commission’s Views On
Prison Management For The Judgments Of Law Enforcement.......... 27

C.

The Communications Act Does Not Authorize The
Commission To Interfere With State And Local Prison
Management. ....................................................................................... 32

The Order Is Arbitrary And Capricious Because It Does Not Account
For Significant Costs And Disregards The Record. ...................................... 39
A.

The Order Fails To Account For Differences Across
Correctional Facilities Of Different Sizes. .......................................... 39

B.

The Order Fails To Account For The Costs Of Adequate
Security Measures. .............................................................................. 42

C.

The Order Conflicts With Record Evidence Establishing That
The Commission’s Rates Are Unreasonably Low. ............................. 44

The Order Impermissibly Abrogates Existing Contracts For Inmate
Calling Services. ............................................................................................ 45

CONCLUSION ........................................................................................................ 47
RULE ECF-3(B) ATTESTATION
CERTIFICATE OF COMPLIANCE
ADDENDUM OF STATUTORY PROVISIONS
CERTIFICATE OF SERVICE

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TABLE OF AUTHORITIES
Page(s)
Cases
Arsberry v. Illinois,
244 F.3d 558 (7th Cir. 2001) ......................................................................... 25, 28
Bell v. Wolfish,
441 U.S. 520 (1979) ...................................................................................... 23, 39
*Business Roundtable v. SEC,
905 F.2d 406 (D.C. Cir. 1990) ........................................ 16, 32, 33, 34, 36, 37, 38
California v. FCC,
798 F.2d 1515 (D.C. Cir. 1986) ...........................................................................22
*Cellco P’ship v. FCC,
700 F.3d 534 (D.C. Cir. 2012) ...................................................................... 45, 46
Chevron U.S.A., Inc. v. Natural Res. Def. Council, Inc.,
467 U.S. 837 (1984) ...................................................................................... 15, 16
Gonzales v. Oregon,
546 U.S. 243 (2006) ...................................................................................... 16, 44
*Gregory v. Ashcroft,
501 U.S. 452 (1991) .................................................................... 16, 32, 33, 36, 38
Holloway v. Magness,
666 F.3d 1076 (8th Cir. 2012) ..............................................................................28
Jones v. N.C. Prisoners’ Labor Union, Inc.,
433 U.S. 119 (1977) .............................................................................................23
Medtronic, Inc. v. Lohr,
518 U.S. 470 (1996) .............................................................................................32

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(continued)
Page(s)
*Motor Vehicle Mfrs. Ass’n of U.S., Inc. v.
State Farm Mut. Auto. Ins. Co.,
463 U.S. 29 (1983) ...................................................................... 16, 39, 41, 42, 45
*NAACP v. Fed. Power Comm’n,
425 U.S. 662 (1976) .................................................................... 16, 32, 34, 37, 38
Nat’l Tel. Coop. Ass’n v. FCC,
563 F.3d 536 (D.C. Cir. 2009) .............................................................................39
Preiser v. Rodriguez,
411 U.S. 475 (1973) .............................................................................................23
*Regents of University System of Georgia v. Carroll,
338 U.S. 586 (1950) .............................................................................................45
Schuette v. BAMN,
134 S. Ct. 1623 (2014) .................................................................................. 23, 29
SEC v. Chenery,
318 U.S. 80 (1943) ...............................................................................................36
Smith v. Robbins,
528 U.S. 259 (2000) ................................................................................ 11, 12, 24
Will v. Mich. Dep’t of State Police,
491 U.S. 58 (1989) ...............................................................................................32
Wyeth v. Levine,
555 U.S. 555 (2009) .............................................................................................32
Federal Statutes
5 U.S.C. § 706(2) .....................................................................................................16
28 U.S.C. § 2342(1) ...................................................................................................5
28 U.S.C. § 2343 ........................................................................................................5
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(continued)
Page(s)
28 U.S.C. § 2344 ................................................................................................. 5, 21
47 U.S.C. § 151 ........................................................................................... 17, 22, 38
*47 U.S.C. § 201(b) .......................................................................................... 33, 34
*47 U.S.C. § 276(b)(1)...................................................................................... 36, 37
47 U.S.C. § 276(c) ...................................................................................................36
47 U.S.C. § 402(a) .............................................................................................. 5, 21
47 U.S.C. §§ 151-162 ..............................................................................................38
State Statutes
Ariz. Rev. Stat. Ann. § 41-1604.03 ..........................................................................11
Cal. Penal Code § 4025 ............................................................................................11
Ind. Code § 5-22-23-7(a) .........................................................................................11
Mass. Gen. Laws ch. 127, § 3 ..................................................................................24
Miss. Code Ann. § 47-5-158 ....................................................................................25
Miss. Code Ann. § 47-5-23 ......................................................................................24
N.H. Rev. Stat. Ann. § 30-B:4 .................................................................................24
Ohio Rev. Code Ann. § 5120.132 ............................................................................11
S.C. Code Ann. § 24-5-80 ........................................................................................24
S.D. Codified Laws § 24-1-4 ...................................................................................24
Tex. Gov’t Code Ann. § 495.027(a) ................................................................. 12, 30
Va. Code Ann. § 53.1-68(A) ....................................................................................24
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(continued)
Page(s)
Regulations
47 C.F.R. § 64.6010 ...................................................................................................1
47 C.F.R. § 64.6020 ...................................................................................................1
47 C.F.R. § 64.6060 ...................................................................................................1
78 Fed. Reg. 4,369 (Jan. 22, 2013) ................................................................... 12, 13
78 Fed. Reg. 67,956 (Nov. 13, 2013) ........................................................................5
Rule
Fed. R. App. P. 15(d) .................................................................................................5

* Authorities upon which we chiefly rely are marked with asterisks.

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GLOSSARY
Commission

Federal Communications Commission

FCC

Federal Communications Commission

ICS

Inmate Calling Services

Order

Report and Order and Further Notice
of Proposed Rulemaking, Rates for
Interstate Inmate Calling Services,
WC Docket No. 12-375, FCC 13-113

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INTRODUCTION
On January 13, 2014, this Court stayed key elements of the Commission’s
new rules for interstate prisoner telephone calls, see Report and Order and Further
Notice of Proposed Rulemaking, Rates for Interstate Inmate Calling Services, WC
Docket No. 12-375, FCC 13-113 (“Order”), finding that “the stringent
1

requirements for a stay pending court review” were met.

Now, petitioners

Arizona Department of Corrections, Mississippi Department of Corrections, and
South Dakota Department of Corrections, and their supporting intervenors
Arkansas Department of Correction, Indiana Department of Correction, and
Barnstable County Sheriff’s Office (collectively, the “Correctional Facilities”),
respectfully ask this Court to vacate the Order.
The providers of inmate calling services well explain the various legal
problems with the Order—including the flaws in the cost-based rate-making
requirement. See Joint Brief for the ICS Provider Petitioners and Supporting
Intervenor (“Provider Brief”). The Correctional Facilities adopt those arguments
and expand on the case from the unique perspective of law enforcement,
demonstrating the ways in which the Order invades and upends their governmental
authority over prison management.

1

Stay Order at 1, Securus Techs., Inc. v. FCC, No. 13-1280 (Jan. 13, 2014)
(granting motions for stay as to cost-based rule, 47 C.F.R. § 64.6010, safe harbor
rule, id. § 64.6020, and annual reporting requirement, id. § 64.6060).
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The Order intrudes far into the core domain of state and local correctional
facilities, state legislatures, and local governments to craft and administer their
own penal, rehabilitative, and budgetary policy. Although the Commission will
likely defend the Order, as it did in the stay proceedings, as a routine exercise of
its authority over interstate telephone rates, the Order belies that contention: It is
explicitly premised on the breathtakingly sweeping purpose of “promot[ing] the
general welfare of our nation,” JA__ [Order_¶_2], and unabashedly takes up and
resolves questions of penological policy based on its own normative judgments
about who should pay for the costs of prisoner calls and inmate welfare programs,
and how much security is really needed for such calls, see JA__
[Order_¶¶_3,_7,_54].
Specifically, in imposing unreasonably low rate caps and mandating costbased rates beneath those caps for prisoners’ interstate calls, the Order claims to
ease the way for prisoners to communicate with family and friends—in order to,
among other things, reduce recidivism, strengthen prisoners’ legal representation,
and save money for the criminal justice system. Those goals fall well outside the
Commission’s delegated authority and technical expertise over interstate
telecommunications.
Moreover, the Order will have the opposite effect than that claimed by the
Commission.

The new rate caps and rate-of-return regulations will make it

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difficult if not impossible for service providers to cover their costs at many
facilities, and will thus threaten their ability and the ability of correctional facilities
to provide the costly security measures for prisoner calls needed to ensure the
safety of the public. The Order will jeopardize inmate calling services altogether
at many facilities. And to the extent that facilities maintain such services, many
will be saddled with outmoded, substandard security equipment.
On top of imperiling the phone service that the Order deems so critical and
imperiling public safety, the Order sounds the death knell for many programs
designed by state and local governments to assist inmates. The Order does so by
effectively eliminating site commissions—legitimate payments made to many
correctional facilities as part of phone-service contracts—that are necessary to fund
a wide array of programs and services that benefit prisoners. In doing so, the
Commission arrogates to itself the policy judgments of how to properly fund such
programs and whether those programs should exist at all. Those questions are for
state and local correctional officials, not a federal agency charged with regulating
interstate telecommunications. As Commissioner Pai emphasized in dissent, the
Commission’s intrusion into the rehabilitative process will inflict wide-reaching
harm—on the public, the officials who manage the Nation’s correctional facilities,
the prisoners whose interests the Order purports to advance, and the traditional
balance of authority between the federal government and state authorities.

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Accordingly, in addition to the reasons set forth in the Provider Brief, the
Order should be vacated on the following independent grounds. First, the Order
exceeds the Commission’s authority by substituting the Commission’s opinions
about sound prison administration for the considered judgments of the state and
local officials responsible for overseeing the Nation’s inmate populations. Second,
the Order is arbitrary and capricious because the Commission failed to consider
the materially different circumstances that various facilities face when attempting
to keep prisoners and the public safe, the significant costs of essential security
measures, and record evidence demonstrating that the rate caps and safe harbors
imposed by the Order are unrealistically low. Third, the Order impermissibly
abrogates existing contracts between inmate calling service providers and
correctional facilities that provide for site commissions.
If the Order is not vacated, it will inflict sweeping harm on correctional
facilities, the public, and prisoners. The Order stands to disrupt critical and everevolving security measures that protect the public and will halt many programs that
actually help to rehabilitate criminal offenders. It will also cause upheaval in the
budgets of those States that have long relied on site-commission revenue to pursue
rehabilitative goals and other legitimate objectives.

And by making it

economically infeasible—or too dangerous—to provide inmate calling services at
all in many facilities, the Order is ultimately self-defeating.

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STATEMENT OF JURISDICTION
This Court has jurisdiction under 47 U.S.C. § 402(a) and 28 U.S.C.
§ 2342(1). This venue is proper under 28 U.S.C. § 2343.
The Order was published in the Federal Register on November 13, 2013.
See 78 Fed. Reg. 67,956 (Nov. 13, 2013).

The Mississippi Department of

Corrections and South Dakota Department of Corrections filed timely petitions for
review on December 9, 2013, and the Arizona Department of Corrections filed a
timely petition for review on January 13, 2014. See 28 U.S.C. § 2344. Because
the Arizona Department of Corrections filed its petition for review on January 13,
2014, the period to file a motion for leave to intervene ran through February 12,
2014. See Fed. R. App. P. 15(d). The Arkansas Department of Correction filed a
timely motion to intervene on December 13, 2013; the Indiana Department of
Correction filed a timely motion to intervene on February 11, 2014; and the
Barnstable County Sheriff’s Office filed a timely motion to intervene on January
2

28, 2014.

STATEMENT OF THE ISSUES
1.

Whether the Order, by effectively prohibiting site commissions and

by mandating rates at levels that threaten to make critical security features for
2

This Court granted all of these motions. See Order at 1, Securus Techs., Inc. v.
FCC, No. 13-1280 (Mar. 10, 2014) (Indiana Department of Correction and
Barnstable County Sheriff’s Office); Order at 1, Securus Techs., Inc. v. FCC, No.
13-1280 (Jan. 7, 2014) (Arkansas Department of Correction).
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inmate calls cost-prohibitive, unlawfully intrudes on the prerogatives of state and
local authorities to manage correctional facilities and thereby exceeds the
Commission’s authority.
2.

Whether the Order is arbitrary, capricious, or contrary to law because

the Commission failed to adequately consider the costs of providing inmate calling
services.
3.

Whether the Order is arbitrary, capricious, or contrary to law in its

application to existing contracts between correctional facilities and providers of
inmate calling services.
STATUTES AND REGULATIONS
Pertinent statutes are reproduced in the addendum to this brief. Pertinent
regulations appear in the Order.
STATEMENT OF THE CASE
The background of this case is set forth in the Statement of the Case in the
Provider Brief. The Correctional Facilities adopt that Statement and focus here on
additional background relevant to their challenges to the Order.
A.

Inmate Calling Services Require States And Localities To Deploy
Sophisticated Security Measures In Order To Keep The Public
Safe.

Inmate calling services present unique and complex security challenges.
The record establishes that inmates use their calling privileges to “plot and plan

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criminal enterprises . . . literally every day.”
_Ass’n_3/25/2013_Comment].

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JA__ [National_Sheriffs’

In some facilities, inmates have used calling

privileges to smuggle in drugs and weapons and to plot crimes with outside
confederates.

JA__ [Epps_Decl._¶_5;_Kaemingk_Decl._¶_5].

At others,

prisoners have used phone calls to coordinate gang activity with inmates housed at
other facilities, organize large-scale drug deals and violent crimes, and improperly
contact victims, witnesses, and judges.

JA__ [Order_¶_58_n.216].

As the

National Sheriffs’ Association explained here, “[t]here are dangerous individuals
in local jails who, via ICS, try to continue their criminal activities on the outside
while

they

are

incarcerated.”

[National_Sheriffs’_Ass’n_3/25/2013_Comment].

JA__

All of this happens with

“startling regularity.” JA__ [National_Sheriffs’_Ass’n_3/25/2013_Comment].
Faced with these dangers, law enforcement officials have deployed a broad
arsenal of sophisticated security measures to protect the public, prison personnel,
and inmates themselves. Correctional facilities record inmate calls to monitor
illicit activity. JA__ [National_Sheriffs’_Ass’n_Opening_Testimony]. To ensure
that inmates communicate only with approved persons, facilities must install
technology that blocks inmates from calling unapproved numbers, must disable
call forwarding and call transferring, and must prevent those communicating with
inmates from using conference-call capabilities to include unauthorized

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Order on Remand & Notice of Proposed Rulemaking,

Implementation of the Pay Telephone Reclassification and Compensation
Provisions of the Telecommunications Act of 1996, 17 FCC Rcd. 3248, 3252; JA__
[Order_¶_85_&_n.321]. Correctional facilities use voice identification technology
to verify the identity of the person speaking. JA__ [Dissent_at_124]. Officials
prepare and analyze detailed reports documenting inmates’ phone use to detect
patterns indicating that inmates are using their calling privileges for improper
purposes. Order on Remand & Notice of Proposed Rulemaking, 17 FCC Rcd. at
3252. And law enforcement officials must frequently update security systems to
ensure that they remain effective against inmates who continually attempt to
circumvent

existing

security

measures.

JA__

[National_Sheriffs’_Ass’n_3/25/2013_Comment].
These security measures make inmate phone calls considerably more costly
than ordinary calls for the general public. Although costs vary by facility, charges
for inmate phone calls can cost up to $0.89 per minute and may include further
per-call charges up to $3.95. JA__ [Order_¶_85]. The security technology itself is
expensive, and providers also incur costs for setting up and administering payment
features for each inmate who uses phone service. JA__ [Ex_Parte_Presentation_of
PayTel_Telecomms._at_3].
personnel

to

Correctional facilities must also hire additional
monitor

calls.

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[National_Sheriffs’_Ass’n_Opening_Testimony]. The set-up and administration
costs of phone service are even higher at smaller facilities because they have
higher

turnover

rates

than

larger

facilities.

JA__

[Ex_Parte_Presentation_of_PayTel_Telecomms._at_3]. And small facilities must
install many of the same expensive security features as large facilities, causing
them to incur the same costs as large facilities but with less call volume to defray
those costs. See JA__ [Order_¶_77].
Although expensive, these security measures are essential.

Law

enforcement officials describe them as “a vital tool in our effort to combat
continued criminal enterprise[s], smuggling of contraband, witness intimidation,
narcotics trafficking, violent crime, recapture of escaped inmates, and even interfacility

communications

between

prison

gangs.”

JA__

[Epps_Decl._¶_5;_Kaemingk_Decl._¶_5].
B.

In Accordance With Their Authority To Administer Correctional
Facilities, Many States And Localities Require Inmate Calling
Service Providers To Pay Site Commissions In Order To Fund
Correctional Budgets.

Just as States and localities have determined that extensive security
measures are necessary to providing inmate calling services, they have also
determined that they should, through inmate calling service contracts, recover
some of the substantial costs of maintaining correctional facilities, housing and
providing

for

prisoners,

and

rehabilitating
9

inmates.

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[Miss._Dep’t_of_Corrections_3/5/2013_Comment;_Louisiana_Dep’t_of_Public_S
afety_&_Corrections_3/22/2013_Comment,_at_3-5]. Correctional facilities have
implemented this judgment by requiring inmate calling service providers to pay
site commissions—payments made to many correctional facilities as part of phoneservice contracts. JA__ [Order_¶_33].
States and localities use site-commission funds to recover costs associated
with inmate programs and with providing inmate calling services. Among other
goals, the funds help States and localities “to recoup the administration costs of
inmate calling services,” including the cost of maintaining security features and of
buying

new

phone

equipment.

JA__

[National_Sheriffs’_Ass’n_Opening_Testimony;_Epps_Decl._¶_11]. Funds from
site commissions are also used to maintain correctional facilities, to hire and train
prison personnel, and to buy athletic supplies, recreational equipment, library
resources, and subscriptions to periodicals—all to benefit inmates.

JA__

[Epps_Decl._¶_8;_Kaemingk_Decl._¶_ 8;_National_Sheriffs’_Ass’n_Opening_Te
stimony]. Site commissions are also a crucial—and sometimes the sole—source of
funding for inmate welfare programs, including life-skills programs, GED
programs, vocational training and reentry programs, and mental counseling
programs.

JA__ [Epps_Decl._¶_8;_Kaemingk_Decl._¶_8].

If correctional

facilities were unable to collect these commissions, law enforcement officials

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would need to find alternative sources of funding (likely by raising taxes), cut their
budgets, or scale back or eliminate these valuable programs.

JA__

[Epps_Decl._¶ 12;_Kaemingk_Decl._¶ 12].
In keeping with their broad discretion “to experiment with solutions to
difficult problems of policy,” Smith v. Robbins, 528 U.S. 259, 273 (2000), States
have reached different judgments on the propriety and necessity of site
commissions. Most States have concluded that site commissions are important to
their objectives and that correctional facilities may properly insist upon them—on
the judgment, for example, that offenders and their families benefit from services
funded

by

site

commissions.

JA__

[Louisiana_Dep’t_of_Public_Safety_&_Corrections_3/22/2013_Comment,_at_3].

3

Several States have, by contrast, regulated site commissions more extensively.
Some States have capped the amount facilities may collect in site commissions,
and

seven

States

have

banned

site

3

commissions

completely.

JA__

See Ariz. Rev. Stat. Ann. § 41-1604.03 (inmate calling services funds used for
“building renewal” and “[t]he benefit, education and welfare of committed
offenders” including “operation of canteens and hobby shops”); Cal. Penal Code
§ 4025 (inmate welfare fund used “for the benefit, education, and welfare of . . .
inmates” and “for the maintenance of county jail facilities”); Ind. Code § 5-22-237(a) (inmate calling services funds aimed at “improving, repairing, rehabilitation,
and equipping department of correction facilities”); Ohio Rev. Code Ann.
§ 5120.132 (inmate calling services money used for education, building
maintenance, salary, and paying vendors who participate in inmate welfare
programs).
For a list of state statutes in the record, see JA__
[Reply_Comment_of_Martha_Wright,_Ex._H_4/22/2013].
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[Order_¶_33,_37]. Still other States have reached different judgments about the
role of site commissions in their budgetary and penal objectives.

Texas, for

example, requires that its correctional facilities collect site commissions. See Tex.
Gov’t Code Ann. § 495.027(a).
In all events, States are mindful that inmate phone calls involve higher costs,
and thus some States that permit site commissions have sought to reduce the price
of

these

calls

while

maintaining

security.

JA__

[South_Dakota_Dep’t_of_Corrections_3/21/2013_Comment] (noting that South
Dakota added debit calling options to reduce the price of calls).

States’

“experiment[s]” with potential “solutions” to these “difficult problems” thus
continue. Robbins, 528 U.S. at 273.
C.

The Order Displaces The Judgments Of States And Localities
Regarding Sound Prison Management.

In 2003 and again in 2007, public interest groups and people with
incarcerated family members petitioned the Commission to issue regulations
reducing the costs of inmates’ interstate phone calls. JA__ [Order_¶_9]. The
Commission provided notice and received comment on both petitions, 78 Fed.
Reg. 4,369, 4,371 (Jan. 22, 2013), but did not act further on either. Although no
new factual developments warranted reconsidering this issue, in late 2012 the
Commission revived these rulemaking petitions on its own. See id. at 4,369-70.

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From the start, the Commission was apparently driven by its own view of
appropriate penal policy. In its Notice of Proposed Rulemaking, for example, the
Commission ventured that “regular telephone contact between inmates and their
families is an important public policy matter,” and that, in determining whether to
issue a final rule, it would “consider the impact that interstate ICS rates have” on
the ability of inmates to stay in touch with family members and friends. 78 Fed.
Reg. at 4,370; see also JA__ [Order_¶¶_3-4].
When it adopted the Order, the Commission asserted that its action “will
promote the general welfare of our nation by making it easier for inmates to stay
connected,” which would “lower recidivism rates” and, in turn, produce “fewer
crimes, decreas[e] the need for additional correctional facilities, and reduc[e] . . .
overall costs to society.” JA__ [Order_¶_2]. The Commission catalogued “the
societal

impacts”

of

high

rates

for

inmate

calling

services,

JA__

[Order_¶¶_20,_42-44], and relied upon sociological studies (of dubious validity to
begin

with)

and

data

about

attorney-client

phone

use,

JA__

[Order_¶¶ 32,_43,_131]. The Commission claimed that the Order would save the
criminal justice system “between $60 and $70 billion per year nationwide” based
on reduced rates of recidivism. JA__ [Order_¶_43].
“[T]o ensure that these benefits . . . are realized,” JA__ [Order_¶_44], the
Commission established rate caps for interstate debit and collect calls and required

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JA__ [Order_¶¶_5,_53-60,_73,_90].

Beneath the caps, the Order establishes what it describes as “safe harbor” rates.
JA__ [Order_¶_60]. The Commission was clear, however, that rates at or below
the “safe harbors” are only presumed reasonable, and thus a provider has no
guarantee that the Commission would not find its rates unreasonable if
challenged—a finding that would purportedly subject a provider to significant
penalties. JA__ [Order_¶¶_5,_119].
Although the Order purports to account for security costs necessary to
ensure that inmates do not use their phone privileges for ill, the Order states only
that providers will likely be able to recover certain costs for “[s]ecurity features
inherent in the ICS providers’ network,” such as call recording and call blocking.
JA__ [Order_¶ 53_&_n.196]. Critically for correctional institutions, moreover, the
Order provides that the cost of site commissions must not be included in rates for
interstate calls.

JA__ [Order_¶_54].

The Commission maintained that this

prohibition would not technically bar correctional facilities from collecting site
commissions. JA__ [Order_¶_56]. The Commission acknowledged, however,
that the Order would have the effect of eliminating “some or all” of the programs
funded by site commissions. JA__ [Order_¶_57]. It also recognized the need for
“renegotiat[ing]” existing contracts or “terminat[ing] existing contracts so they can

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be rebid based on revised terms that take into account the Commission’s
requirements” under the Order. JA__ [Order_¶_102].
D.

This Court Stays Key Elements Of The Order.

With the Order poised to take effect on February 11, 2014, the Mississippi
Department of Corrections and South Dakota Department of Corrections, together
with certain service providers (CenturyLink Public Communications, Inc., Global
Tel*Link Corp., and Securus Technologies, Inc.), moved to stay the Order pending
judicial review. On January 13, 2014, a panel of this Court stayed key elements of
the Order, finding that “the stringent requirements for a stay pending court review”
were met. Stay Order at 1, Securus Techs., Inc. v. FCC, No. 13-1280 (Jan. 13,
2014).

The Court halted implementation of the “safe harbor” rates, the

requirement that rates be cost-based, and the prohibition on recovering site
commissions. Id. The Court left in place the rate caps, which are now in effect;
Judge Brown would have stayed those caps too. Id.
STANDARD OF REVIEW
In evaluating whether the Commission exceeded its authority, this Court
applies the Chevron framework. The Commission is bound by Congress’s clearly
expressed intent. Chevron U.S.A., Inc. v. Natural Res. Def. Council, Inc., 467 U.S.
837, 842 (1984). If Congress has not spoken to the precise question at issue, “the

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question for the court is whether the agency’s answer is based on a permissible
construction of the statute.” Id. at 843.
Where the proffered interpretation of a federal statute would infringe rights
traditionally reserved to the States, however, congressional intent must be
“unmistakably clear.” Gregory v. Ashcroft, 501 U.S. 452, 460 (1991) (internal
quotation marks omitted). The Commission therefore may not rely on generalized
statutory terms to “invad[e] . . . firmly established state jurisdiction.” Business
Roundtable v. SEC, 905 F.2d 406, 413 (D.C. Cir. 1990) (internal quotation marks
omitted); see also NAACP v. Fed. Power Comm’n, 425 U.S. 662, 669 (1976).
This Court will vacate a Commission order that is contrary to law, arbitrary
and capricious, or unsupported by evidence. See 5 U.S.C. § 706(2). An order is
arbitrary or capricious if the Commission has “relied on factors which Congress
has not intended it to consider, entirely failed to consider an important aspect of the
problem, [or] offered an explanation for its decision that runs counter to the
evidence before the agency.” Motor Vehicle Mfrs. Ass’n of U.S., Inc. v. State Farm
Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983).
Any deference afforded to the Commission’s factual findings “is tempered”
when the agency lacks expertise in the area that it has sought to regulate. Gonzales
v. Oregon, 546 U.S. 243, 269 (2006).

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SUMMARY OF ARGUMENT
Inmate phone calls are a privilege, not a right. They can be used for ill—for
instance, to plot crimes with outside confederates or coordinate gang activity at
other prisons—as well as for good. Managing these communications lies at the
heart of the Correctional Facilities’ authority and obligations under state and local
law. The Commission had no warrant to interfere with those legitimate interests
by interjecting itself into prison administration under the guise of regulating
interstate telephone rates. The legal impropriety of that interference is traceable to
three fatal flaws in the Order.
First, the Order exceeds the Commission’s authority by intruding on the
prerogatives of state and local authorities. State and local authorities are entrusted
with managing their own correctional facilities. In exercising that authority to
provide inmate calling services, many States and localities have deemed it
necessary to charge site commissions to fund inmate welfare programs, and to
employ extensive but costly security measures to protect the public, prison
personnel, and inmates themselves. These are legitimate judgments that state and
local officials are entitled to make.

By contrast, the Commission enjoys no

authority, experience, or expertise in administering correctional facilities but
instead is tasked with “regulating interstate and foreign commerce in
communication by wire and radio.” 47 U.S.C. § 151.

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The Order upends the valid penal and budgetary policy judgments reached
by States and localities. The Order displaces state and local law enforcement
officials’ judgments as to the appropriate manner of funding inmate welfare
programs, thereby making it more difficult for correctional institutions to make
those programs available at all. States and localities have authority to decide
whether and how prisoner welfare programs are to be funded, and many, acting
through their legislative process, have chosen to fund such programs through site
commissions. But the Commission excluded site commissions from the costs that
can be recovered from inmate calling services based on the normative and
conflicting policy judgment that prisoners should not bear those costs. Further, the
Order undermines the determination of state and local authorities that advanced
security measures are essential to protecting the public, prison officials, and
prisoners. The unreasonably low rate caps and rate-of-return regulation imposed
by the Order do not account for the staggering and increasing costs of ensuring
that inmate calling services can be provided safely.
None of the statutory provisions invoked by the Commission supports its
assertion of authority to displace state and local policy judgments on penal
administration. To justify the Order, the Commission would need to point to an
“unmistakably clear” grant of statutory authority to alter the customary balance of
power between the federal government and the States. None of the provisions

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invoked by the Commission—Section 201(b), Section 276, or Title I of the
Communications Act—makes such an unmistakably clear statement.

This

confirms that Congress never envisioned that the Commission would attempt to
use its authority under the Communications Act to meddle in an area as
fundamental to States and localities as prison management and related budgetary
policy. Contrary to the explicit premise of the Order, the Communications Act
contains no “general welfare clause,” much less a provision that allows the
Commission to substitute its judgment on matters of penal policy for that of state
and local governments.
Second, the Order is arbitrary and capricious in several respects. The Order
fails to account for material differences across correctional facilities and, in doing
so, defeats two of the Commission’s primary goals in issuing the Order. The
record establishes that the cost of phone calls varies dramatically across facilities
of different sizes. By imposing uniform rate requirements for all facilities, the
Order ignores these material differences, and ensures that—contrary to the
Commission’s own stated purpose—the rates imposed by the Order are not costbased. And by mandating below-cost rates at some facilities, the Order will cause
providers to stop offering phone service at those facilities. This will ensure that—
again contrary to the Commission’s avowed purpose—the Order will actually
impede inmate access to phone service at these facilities.

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The Order also fails to reasonably account for the costs of security measures
associated with inmate calling services. The unreasonably low rates established by
the Order will prevent state and local officials from deploying advanced security
measures that are essential to ensuring the safety of the public, prison personnel,
and inmates themselves. And the Order will deter the development of new, more
advanced security measures because they will be too expensive under the Order.
Finally, the Order conflicts with the record, which demonstrates that the rate
caps imposed by the Commission’s regulations are unreasonably low. The record
establishes that the public pays more for collect calls than prisoners would under
the Order—even though ordinary collect calls do not demand the sophisticated and
higher-cost security measures that inmate calls require. The Commission ignored
this evidence.
Third, the Order exceeds the Commission’s authority by abrogating existing
contracts. It does so by effectively prohibiting site commissions, which renders
existing contracts between providers and correctional facilities impossible to honor
and economically infeasible to continue.
For these reasons, the Order should be vacated.
STATEMENT OF STANDING
The Order aggrieves and otherwise injures the Correctional Facilities. The
Order effectively bans site commissions by prohibiting inmate calling service

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providers from recovering those costs, thus decreasing or eliminating this revenue
for the Correctional Facilities. JA__ [Order_¶_54]. The loss of revenue from site
commissions will make it more difficult for the Correctional Facilities to maintain
the safety of their facilities, hire and train law enforcement personnel, and provide
vocational training and rehabilitation programs to their inmates.
[Epps_Decl._¶_12;_Kaemingk_Decl._¶_12].

JA__

The Order also threatens the

availability of critical security features for inmate calling services.

JA__

[Epps_Decl._¶_5;_Kaemingk_Decl._¶_5]. Finally, the Order affects existing and
future contracts for inmate calling services between the Correctional Facilities and
service providers. The Correctional Facility petitioners have statutory standing
because each participated in, and thus was a party to, the agency proceedings
below. See 47 U.S.C. § 402(a); 28 U.S.C. § 2344.
ARGUMENT
The Order should be vacated. First, the Order exceeds the Commission’s
authority by intruding on the prerogatives of state and local authorities to manage
their prisons and related budgetary affairs and by displacing their legitimate
judgments on those questions.

Second, the Order is arbitrary and capricious

because the Commission failed to consider the materially different circumstances
that different correctional facilities face when attempting to keep prisoners and the
public safe, the significant costs of essential security measures, and record

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evidence demonstrating that the rate caps and safe harbors imposed by the Order
are unrealistically low. Third, the Order exceeds the Commission’s authority
because it impermissibly abrogates existing contracts between inmate calling
service providers and correctional facilities.
I.

The Order Exceeds The Commission’s Authority By Intruding On The
Prerogatives Of State And Local Authorities.
Charged with “regulating interstate and foreign commerce in communication

by wire and radio,” 47 U.S.C. § 151, the Commission lacks authority to intrude on
an area so fundamental to state and local governments as managing their own
correctional facilities and budgets, see, e.g., California v. FCC, 798 F.2d 1515,
1520 (D.C. Cir. 1986). But the Order does just that. By setting rate caps that are
unreasonably low and barring providers from recovering the cost of site
commissions in the rates they charge for interstate calls, as well as failing to clearly
permit recovery for basic security measures, the Order impermissibly interferes
with state and local judgments regarding prison administration and security.
A.

State And Local Authorities—Not The Commission—Are
Entrusted With Administering Their Own Correctional Facilities.

State and local authorities—not the Commission—are entrusted with
managing their own correctional facilities. As the Supreme Court has emphasized,
“[i]t is difficult to imagine an activity in which a State has a stronger interest, or
one that is more intricately bound up with state laws, regulations, and procedures,

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than the administration of its prisons.” Preiser v. Rodriguez, 411 U.S. 475, 491-92
(1973). State and local law enforcement officials—not the Commission—“are
responsible for maintaining internal order and discipline, for securing their
institutions against unauthorized access or escape, and for rehabilitating . . . the
inmates placed in their custody.” Bell v. Wolfish, 441 U.S. 520, 548 n.30 (1979)
(internal quotation marks omitted).
Prison administrators are thus entitled to “wide-ranging deference in the
adoption and execution of policies and practices that in their judgment are needed
to preserve internal order and discipline and to maintain institutional security”
(Bell, 441 U.S. at 547), particularly because the “internal problems of state prisons
involve issues [that are] so peculiarly within state authority and expertise”
(Preiser, 411 U.S. at 492). When a federal agency tramples on state and local
authorities’ decisions on prison administration, it undermines their “important
interest in not being bypassed in the correction of those problems.” Id.; cf. Jones v.
N.C. Prisoners’ Labor Union, Inc., 433 U.S. 119, 126 (1977) (emphasizing the
particular need for federal court “deference to the appropriate prison authorities”
“where state penal institutions are involved” (emphasis added; internal quotation
marks omitted)). Indeed, “[t]here is no authority . . . for the [Commission] to set
aside” judgments that are “commit[ted]” to the States, or to “remov[e]” from the
States’ “reach” the authority to address “sensitive issues” of policy, Schuette v.

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BAMN, 134 S. Ct. 1623, 1638 (2014) (plurality opinion)—such as those involving
prison administration, which lie at the heart of the States’ traditional police powers.
In keeping with their broad discretion “to experiment with solutions to
difficult problems of policy,” Smith v. Robbins, 528 U.S. 259, 273 (2000), many
States have made the policy judgments that: (1) they should provide welfare
programs to rehabilitate inmates, and that the costs of those programs—as well as
the substantial costs of maintaining prisons and offering inmate calling services—
should be recovered in part through site commissions; and (2) although inmate
calling services are important, they demand extensive security measures to protect
the

public,

prison

personnel,

and

inmates.

JA__

[National_Sheriffs’_Ass’n_Opening_Testimony].
Many States grant state correctional departments sole authority over
correctional facilities, including responsibility for rehabilitating prisoners and for
security.

See, e.g., Miss. Code Ann. § 47-5-23 (granting “the exclusive

responsibility for management and control of the correctional system” to the
Department of Corrections); Mass. Gen. Laws ch. 127, § 3 (“Any monies . . .
generated by the sale or purchase of goods or services to persons in the
correctional facilities may be expended for the general welfare of all the inmates at
the discretion of the superintendent [of the facility].”); see also N.H. Rev. Stat.
Ann. § 30-B:4; S.C. Code Ann. § 24-5-80; S.D. Codified Laws § 24-1-4; Va. Code

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Ann. § 53.1-68(A). To rehabilitate prisoners, many correctional facilities fund a
wide array of inmate welfare programs—such as life-skills programs, GED
programs, vocational training and reentry programs, and mental health counseling.
See JA__ [Epps_Decl._¶_8;_Kaemingk_Decl._¶_8].
Because of budget constraints, many of these programs are funded largely—
if not solely—through site commissions. See, e.g., Miss. Code Ann. § 47-5-158
(providing that “[a]ll inmate telephone call commissions shall be paid to the
department” and that “[f]orty percent (40%) of [such] commissions shall be
deposited into the Inmate Welfare Fund”). The costs of site commissions are
passed on, at least in part, to inmates and users of inmate calling services.
Correctional facilities have deemed this appropriate on the judgment that “user[s]”
of prisons—inmates—ought to help “cove[r] the expense[s]” of prison life and the
services that correctional facilities provide, Arsberry v. Illinois, 244 F.3d 558, 564
(7th Cir. 2001) (Posner, J.); in other words, the citizens of these States, acting
through their legislatures, have made the policy choice that these programs should
be funded through revenues generated by the inmate institutions, not supported by
the general taxpayer.
Because of that budgetary and penal judgment, the loss of site commissions
would jeopardize inmate welfare programs. It would also imperil other benefits to
inmates. Site commissions are also used to buy supplies for inmates, including

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library resources, athletic and recreational equipment, and subscriptions to
periodicals. Finally, site commissions are used to defray the costs of providing
calling services, including the cost of administering phone systems, maintaining
security,

and

buying

new

phone

equipment.

JA__

[National_Sheriffs’_Ass’n_Opening_Testimony;_Epps_Decl._¶_11].
Correctional facilities have also reached considered policy judgments on
security related to inmate calling services. To ensure that their facilities remain
safe, state and local prisons have adopted extensive security measures to prevent
inmates from using their calling privileges to commit more crimes. At some
facilities, inmates have attempted to use their calling privileges to smuggle in drugs
and

weapons

and

plot

crimes

[Epps_Decl._¶_5;_Kaemingk_¶_5].

with

criminal

confederates.

JA__

At others, inmates have used calling

privileges to coordinate gang activity with prisoners housed at other facilities,
organize large-scale drug deals and violent crimes, and improperly contact victims,
witnesses, and judges. JA__ [Order_¶_58_n.216]. The record establishes that
inmates attempt to use their phone privileges to “plot and plan criminal enterprises
. . . literally every day,” JA__ [National_Sheriffs’_Ass’n_3/25/2013_Comment].
The security measures chosen and installed by state and local officials prevent
these efforts from succeeding—but add to the expense of inmate calls. See supra
Statement of the Case, Part A.

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The Order Intrudes On The Prerogatives Of State And Local
Authorities By Substituting The Commission’s Views On Prison
Management For The Judgments Of Law Enforcement.

The Order tramples on these legitimate, carefully calibrated choices of state
and local law enforcement officials and of state legislatures.
First, the Order displaces state and local law enforcement officials’
judgments about the availability of inmate welfare programs. States and localities
have authority to decide how prisoner welfare programs are to be funded and many
have chosen to fund such programs through site commissions.

But the

Commission excluded site commissions from the costs that can be recovered from
inmate calling services, based on the purely normative policy judgment that
prisoners should not bear those costs. JA__ [Order_¶_3] (“[S]ite commission
payments, which are often taken directly from provider revenues, have caused
inmates and their friends and families to subsidize . . . inmate welfare”); JA__
[Order_¶_7] (“[W]e find that site commission payments and other provider
expenditures that are not reasonably related to the provision of ICS are not
recoverable through ICS rates, and therefore may not be passed on to inmates and
their friends and families.”).

4

4

Although the Commission has maintained that correctional facilities may still
collect site commissions for the interstate calls at issue, JA__ [Order_¶_100], the
Order makes doing so economically infeasible. The Commission recognized this
when it: (1) acknowledged that the Order would imperil “some or all” of the
programs funded by site commissions; and (2) called for “voluntary renegotiation”
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To begin with, the Commission is wrong to contend that site commissions
are unrelated to the cost of providing inmate calling services or to suggest that they
“are a free revenue stream” to correctional facilities or somehow inappropriate.
Holloway v. Magness, 666 F.3d 1076, 1080 (8th Cir. 2012).

Rather, site-

commission revenues “are a portion of the total cost of the telephone service [that
correctional departments choose] to provide.” Id. Site commissions are legitimate
payments that providers make to correctional facilities for the opportunity to
provide inmate calling services, and are used partly “to recoup the administration
costs

of

inmate

calling

services.”

JA__

[National_Sheriffs’

_Ass’n_Opening_Testimony].
In any event, whatever one may think of the merits of site commissions, that
is a policy judgment that state and local officials—who are charged with managing
their jurisdictions’ correctional facilities, see supra Part I-A—are entitled to make.
The decision of how to “cove[r] the expense of prisons”—“[b]y what[ever]
combination of taxes and user charges” might be deemed best—is not for a federal
agency to make, but is instead one for States and localities “to resolve” for
themselves. Arsberry, 244 F.3d at 566. Those entities have answered the question
in different ways, with many deciding that prisoner calls and other inmate benefits
of contracts. JA__ [Order_¶¶_57,_102]. There would be no reason for sitecommission-funded programs to end—or for parties to renegotiate contracts
requiring site commissions—if correctional facilities could still collect site
commissions.
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self-funding.

See,

Page 41 of 86

e.g.,

JA__

[Louisiana_Dep’t_of_Public_Safety_&_Corrections_3/22/2013_Comment_at_3]
(“[O]ffenders and their families benefit [from] services [funded by site
commissions] and as it was the actions of the offenders that caused their
incarceration, it is only fair that the cost of providing telephone services . . . be
borne by the offenders and their families and not the tax payers at large.”). The
Commission had no authority to decide who should bear the costs of inmate
welfare programs or to otherwise “remov[e]” from the States’ “reach” the authority
to address this “sensitive issu[e]” for themselves, much less overturn their
considered judgments. BAMN, 134 S. Ct. at 1638 (plurality opinion).
In effectively barring payment of site commissions (or large portions of
them) associated with interstate calls by making them unrecoverable, the Order
will deprive correctional institutions of substantial revenues—thereby overriding
state and local budgetary judgments.

For example, the South Dakota and

Mississippi Departments of Corrections receive about $550,000 and $2.3 million
per

year,

respectively,

from

site

commissions.

[Epps_Decl._¶_10;_Kaemingk_Decl._¶_10];
[Global_Tel*Link_Stay_Petition,_Yow_Decl._¶_7].

see

See
also

The

loss

JA__
JA__

of

these

commissions, at least for interstate calls, would hobble the programs that many
States have deemed desirable or necessary to managing their prisons. And nothing

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guarantees that these funds will be—or can be—replaced. As the South Dakota
Department of Corrections explained, “[w]ith federal sequestration and current
economic times in our state, the [Department] has no assurance that our Legislature
would replace the revenue lost by this proposal with taxpayer money.” JA__
[South_Dakota_Dep’t_of_Corrections_3/21/2013_Comment]. What is more, the
Commission never considered the conflict between the Order and state laws
requiring officials to obtain site commissions.

E.g., Tex. Gov’t Code Ann.

§ 495.027(a).
Second, the Order undermines the determination of state and local
authorities that advanced security measures are essential to protecting the public,
prison officials, and prisoners. The unreasonably low rate caps and rate-of-return
regulation imposed by the Order fail to account for the costs of ensuring safety
from the Nation’s inmates. Correctional facilities must not only install advanced
security

features

but

must

also

hire

staff

to

monitor

calls

(JA__

[National_Sheriffs’_Ass’n_Opening_Testimony]), and they must continually
update security systems to keep them effective against inmates determined to
circumvent

existing

security

[National_Sheriffs’_Ass’n_3/25/2013_Comment]).

measures

(JA__

Yet “th[e] rate reduction”

effected by the Order risks making needed security features “cost-prohibitive.”
JA__ [Epps_Decl._¶_6].

The rate reduction may, in particular, “forc[e] ICS

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Providers to cap their rates at a level below what is required to cover the provision
of an integrated ICS/security package that correctional facilities have determined is
necessary”—which could cause many facilities to go without “essential security
features” (JA__ [Epps_Decl._¶_6;_Kaemingk_Decl._¶ _6]) or to reduce prisoners’
phone access to cut costs. The Order makes this clear by providing only a list of
security costs that providers will likely be permitted to recover.

JA__

[Order_¶_53_&_n.196]. Those costs are not clearly recoverable, and any security
measure not enumerated by the Order—such as new and improved technology that
the Correctional Facilities might deem effective—is presumptively not
recoverable.
It is up to “individual jurisdictions to best serve the needs of their inmates,
their

families

and

the

public

at

large.”

[South_Dakota_Dep’t_of_Corrections_3/21/2013_Comment].

JA__

The Commission

lacks the authority or expertise to upset the decisions of state and local officials
striking what they have judged to be the proper balance between prison security
and inmate phone privileges. And the Commission’s foray into regulating state
and local prisons was all the more unwarranted here, in light of ongoing efforts by
States and localities to decrease the price of inmate phone calls while maintaining
what

is,

in

their

judgment,

adequate

security.

[South_Dakota_Dep’t_of_Corrections_3/21/2013_Comment].

31

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The Communications Act Does Not Authorize The Commission
To Interfere With State And Local Prison Management.

The Communications Act does not confer—let alone confer with the
necessary clarity—authority on the Commission to interfere with state and local
correctional policy. As the Supreme Court has emphasized, when congressional
interference with traditional state authority “would upset the usual constitutional
balance of federal and state powers,” “it is incumbent upon the federal courts to be
certain of Congress’ intent before finding that federal law overrides this balance.”
Gregory v. Ashcroft, 501 U.S. 452, 460 (1991) (internal quotation marks omitted).
Congress must therefore make its intent to “alter the usual constitutional balance
between the States and the Federal Government . . . unmistakably clear.” Id.
(internal quotation marks omitted); see, e.g., Wyeth v. Levine, 555 U.S. 555, 565
(2009); Medtronic, Inc. v. Lohr, 518 U.S. 470, 485 (1996); Will v. Mich. Dep’t of
State Police, 491 U.S. 58, 65 (1989).
In harmony with that clear statement rule, this Court has refused to allow
federal agencies to “invad[e] . . . firmly established state jurisdiction” based on
generalized statutory language that does not on its face confer any authority to
invade traditional state prerogatives. Business Roundtable v. SEC, 905 F.2d 406,
413 (D.C. Cir. 1990) (internal quotation marks omitted); see also NAACP v. Fed.
Power Comm’n, 425 U.S. 662, 669 (1976) (“This Court’s cases have consistently
held that the use of the words ‘public interest’ in a regulatory statute is not a broad
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license [to a federal agency] to promote the general public welfare.”). As a result,
the Commission may not rely on generalized statutory terms to claim for itself
authority traditionally reserved to state and local governments.

See Business

Roundtable, 905 F.2d at 413.
The Order triggers this clear statement rule because it would dramatically
upset the balance of federal and state power—arrogating to a federal agency
matters of state and local penal and budgetary policy. See supra Parts I-A, I-B.
And none of the Communications Act provisions relied on by the Commission—
Section 201(b), Section 276, or Title I—contains “unmistakably clear” evidence
that “Congress intend[ed] to alter the usual constitutional balance between the
States and the Federal Government.” Gregory, 501 U.S. at 460 (internal quotation
marks omitted). Even setting aside the federalism problems presented by the
Order, certainly nothing in the Communications Act authorizes the Commission to
“promote the general welfare of our nation,” JA__ [Order_¶_2], or to sit as a
prison reform board.
1.

Section 201.

Section 201(b), invoked repeatedly in the Order,

provides in relevant part: “All charges, practices, classifications, and regulations
for and in connection with [interstate or foreign] communication service, shall be
just and reasonable, and any such charge, practice, classification, or regulation that
is unjust or unreasonable is declared to be unlawful.” 47 U.S.C. § 201(b).

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Section 201(b) contains no clear statement that the Commission may
regulate the inner workings of state and local correctional facilities or make
decisive judgments about the proper administration of state budgets. It provides
instead that rates for interstate and foreign communications services must be “just
and reasonable.” 47 U.S.C. § 201(b). While this grant of authority—to ensure that
rates for interstate and foreign phone service are “just and reasonable”—may be
broad, that does not mean that it is sufficiently clear to allow the Commission to
intrude on state and local decisions regarding “the general public welfare.” Fed.
Power Comm’n, 425 U.S. at 669. Indeed, far from suggesting an intention to
authorize the Commission to “invad[e] . . . firmly established” areas of traditional
state authority, Business Roundtable, 905 F.2d at 413 (internal quotation marks
omitted), Section 201’s language confirms that Congress sought to confine the
Commission to interstate and foreign regulation of communications services—a
matter typically within federal authority.
Although conceding that the Order affects the daily management of the
correctional facilities, the Commission previously contended that the Order
“simply implements” its authority under Section 201 to ensure just and reasonable
rates. Opp. of FCC to Mot. for Stay of Miss. & S.D. Dep’ts of Correction at 5-6;
JA__ [Order_¶_13].

But the Order itself belies any suggestion that the

Commission engaged in a routine assessment of whether ICS rates are “just and

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reasonable.” Rather, as the Order makes clear, the Commission simply believed
that it was wrong, as a matter of social policy, for prisoners and those they call to
pay rates that include the costs of inmate welfare programs. As explained above,
the Order rests on the Commission’s opinion that: (1) the general public should
bear the costs of maintaining correctional facilities, programs, and services, JA__
[Order_¶¶_3,_7,_54]; and (2) only certain features of inmate calling systems are
important enough to be cost-recoverable, JA__ [Order_¶_53_n.196]—a question
implicating core correctional policy and expertise. Likewise, the Order’s other
self-described goals—reducing recidivism, lowering the costs of incarcerating
prisoners, and improving prisoners’ attorney-client relationships—are policy
matters far afield of the Commission’s statutory authorization or expertise. JA__
[Order_¶_2,_42-44]. They are not bona fide attempts to ensure that phone rates
are “just and reasonable,” but penological ends that the Order, reasoning
backwards, tries to shoehorn into Section 201.
2.

Section 276. Section 276 also does not support the Order. Subject to

exceptions not relevant here, Section 276 authorizes the Commission to “establish
a per call compensation plan to ensure that all payphone service providers are
fairly compensated” for each completed call if two conditions are satisfied. Such a
compensation plan must “promote competition among payphone service

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providers” and must “promote the widespread deployment of payphone services to
the benefit of the general public.” 47 U.S.C. § 276(b)(1).
Like Section 201, Section 276 contains no clear statement that the
Commission may regulate the inner workings of state and local correctional
facilities or make judgments about the proper administration of state budgets. See
5

Gregory, 501 U.S. at 460-61. It provides that providers be “fairly compensated”
for providing phone service, but does not remotely suggest a clear intention to
authorize the Commission to “invad[e] . . . firmly established state jurisdiction.”
Business Roundtable, 905 F.2d at 413 (internal quotation marks omitted).
Section 276 also cannot support the Order because the Order does not
satisfy the two prerequisites for Commission action. First, the Order will not
“promote competition among” inmate calling service providers.
§ 276(b)(1).

47 U.S.C.

The Commission maintained that, in the inmate calling services

market, providers are awarded monopolistic contracts that allow them to charge
supposedly excessive rates. JA__ [Order_¶¶_40-41]. The Commission purported
to resolve this issue by imposing rate caps and requiring that all rates be cost5

Although Section 276 includes an express preemption provision for inconsistent
state payphone regulation, see 47 U.S.C. § 276(c), that provision necessarily
applies only to lawfully promulgated FCC regulations. As explained above, the
Order exceeds the substantive grant of authority in Section 276. In any event,
despite citing Section 276(c), the Order never indicates actual reliance on it. See,
e.g., JA__ [Order_¶ _46]. Thus, the Commission is precluded from relying on
Section 276(c) in defense of the Order. See SEC v. Chenery, 318 U.S. 80, 87
(1943).
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But such measures will not “promote competition” among providers.

Rather, the Order simply standardizes the rates that providers will be permitted to
charge. JA__ [Order_¶_5] (adopting rate caps and safe harbor rates applicable to
all correctional facilities). Second, the Order will not “promote the widespread
deployment of payphone services.”

47 U.S.C. § 276(b)(1).

By decreasing

allowable rates, the Order will inhibit facilities that now lack calling systems from
deploying such systems.

The Order’s unreasonably low rates will likewise

decrease access to calling services at many facilities that now have them.
Rather than explaining how the Order satisfies the two prerequisites under
Section 276, the Commission spilled considerable ink arguing why the Order will
benefit the general public. JA__ [Order_¶_51] (explaining that the Order satisfies
the requirements of Section 276 because “cost-based rates help avoid . . . negative
consequences” associated with existing rates for inmate calls). But that just backs
into the problem identified above: the Commission’s unauthorized pursuit of “the
general welfare of our nation” and various “societal” benefits. Section 276’s
language (“fairly compensated”) cannot be read to provide the Commission with “a
broad license to promote the general public welfare” in a way that is disconnected
from the agency’s statutory mandate. Fed. Power Comm’n, 425 U.S. at 669. An
agency never has an “unbounded” mandate to pursue the public interest. Business
Roundtable, 905 F.2d at 413. Even broad statutory language must be tethered to

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the Communications Act’s purposes, see Fed. Power Comm’n, 425 U.S. at 669—
which patently do not include day-to-day prison management.
3.

Title I of the Communications Act, 47 U.S.C. §§ 151-162. The

Commission also ventured that its “exercise of authority under sections 201 and
276 is further informed by the principles of Title I of the Act,” which “states that it
is the Commission’s purpose ‘to make available, so far as possible, to all the
people of the United States’ communications services ‘at reasonable charges.’”
JA__ [Order_¶_15] (quoting 47 U.S.C. § 151). “The regulation of interstate ICS
adopted in this Order,” the Commission maintained, “advances those objectives.”
JA__ [Order_¶_15].
As with Sections 201 and 276, Title I provides no “unmistakably clear”
evidence that the Commission has authority to interfere with state and local
decisions on prison management. Gregory, 501 U.S. at 460 (internal quotation
marks omitted). The Commission’s view of Title I’s “objectives” does not make
up for the Act’s failure to express a clear congressional intention to authorize the
Commission to “invad[e] . . . firmly established state jurisdiction.”

Business

Roundtable, 905 F.2d at 413 (internal quotation marks omitted).
*

*

*

In our federal system, state and local prison authorities—not the
Commission—set the “policies and practices that in their judgment are needed to

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preserve internal order and discipline and to maintain institutional security.” Bell,
441 U.S. at 547. Because nothing in the statutory provisions invoked by the
Commission provides “unmistakably clear” evidence that Congress sought to alter
the usual federal-state balance of power, the Order exceeds the Commission’s
statutory authority.
II.

The Order Is Arbitrary And Capricious Because It Does Not Account
For Significant Costs And Disregards The Record.
An agency rule is invalid when the agency “entirely fail[s] to consider an

important aspect of the problem” or “offer[s] an explanation for its decision that
runs counter to the evidence before [it].” Motor Vehicle Mfrs. Ass’n of U.S., Inc. v.
State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see Nat’l Tel. Coop. Ass’n
v. FCC, 563 F.3d 536, 540 (D.C. Cir. 2009). The Order flunks these criteria.
A.

The Order Fails To Account For Differences Across Correctional
Facilities Of Different Sizes.

In imposing rate caps and “safe harbors,” the Commission failed to account
for the fact that calls at small correctional facilities cost more than calls at large
correctional facilities. JA__ [American_Correctional_Ass’n__10/30/2013_Letter].
Providers incur costs for setting up and administering payment features for each
inmate

who

uses

phone

service.

JA__

[Ex_Parte_Presentation_of_PayTel_Telecomms._at_3]. These costs are higher at
small correctional facilities because of their higher inmate turnover rates, which in

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turn require providers to perform more account maintenance for these facilities.
JA__ [Ex_Parte_Presentation_of_PayTel_Telecomms._at_3]. And providers must
install costly security measures at all facilities they serve, but because smaller
facilities have fewer calls to defray those costs, costs per call are higher.
In imposing rate caps and “safe harbors,” the Commission failed to consider
the significant differences across correctional facilities and how those differences
materially affect the cost structures of service at different facilities. Correctional
facilities vary by size, security levels, and population characteristics (such as
average duration of incarceration). Some facilities are located in rural locations far
from prisoners’ homes, while others impose security procedures that make it
difficult or nearly impossible for inmates to receive regular visitors.
[South_Dakota_Dep’t_of_Corrections_3/21/2013_Comment_at_1].

JA__

These and

other factors affect the level of phone use at a facility (both in the number and
duration of calls) and thus the revenue that will be generated to offset costs. See
JA__ [Dissent_at_117]. Indeed, costs at some small facilities far exceed the rate
caps required by the Order, even excluding the cost of site commissions. See
Provider Brief, Part II-A-1. Although the Commission recognized that calls are
more expensive at smaller facilities, JA__ [Order_¶¶_26,_81], the Order
nonetheless imposes across-the-board rate requirements without regard to facility
size.

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The failure to take this material record evidence into account is arbitrary and
capricious, State Farm, 463 U.S. at 43, particularly because this deficiency
prevents the Order from achieving two of its professed objectives.
First, the Order is meant to improve access to phone service. But the Order
will have the opposite effect at small correctional facilities to the extent that
providers will be unable to afford the costs of providing service at those facilities.
The Commission tried to paper over this problem by explaining that even if a
provider does not recover its costs at small facilities, its losses will be offset by
profits at large facilities. JA__ [Order_¶_80_n.301] (explaining that “even if a
provider may under-recover [costs] at some facilities, it may over-recover [costs]
at others”).

That is, the Commission assumed that providers will voluntarily

absorb losses at small facilities. The Commission gave no reason to support that
implausible assumption, or to overcome the obvious objection: that providers may
simply stop providing phone service at facilities where they lose money. See
Provider Brief, Part II-B.
Second, the Commission’s one-size-fits-all approach defeats its stated
(though, as the providers explain, improper) goal that rates be cost-based. See,
e.g., JA__ [Order_¶¶_5_&_n.19,_7,_12,_47,_50].

If, as the Commission

imagines, the Order does not reduce phone access at some small facilities, then
inmates at larger facilities will effectively subsidize calls made by inmates at

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smaller facilities. That is not the cost-based approach that the Commission insisted
that it was providing—and the Commission thus failed to make “a rational
connection” between the record evidence and “the choice” it “made.” State Farm,
463 U.S. at 43 (internal quotation marks omitted).
B.

The Order Fails To Account For The Costs Of Adequate Security
Measures.

The Commission also failed to adequately consider the significant costs of
necessary security measures. The Order assumes, for example, that the cost of
security features will decline. JA__ [Order_¶_71] (assuming, without evidence,
that “innovation will continue to drive down costs through automation and
centralization”). But the Commission’s analysis fails to consider the broader effect
of its low rates. The low rates set by the Order will make it impossible for many
prisons to deploy more advanced—and costlier—measures that already exist.
JA__ [Dissent_at_129].

Such technologies are designed to combat specific

practices used by inmates to circumvent common security measures.

JA__

[Dissent_at_129]. But the rate caps imposed by the Order will, in many cases, fail
to cover these costs. Law enforcement commenters thus emphasized the need to
fully account for the “security costs associated with the provision of ICS” and “the
security

risks

posed

by”

failing

to

do

so.

JA__

[National_Sheriffs’_Ass’n_7/31/2013_Letter;_Alabama_Sheriffs_Ass’n_
Comment_Apr._22,_2013] (“The revenue from inmate phone calls pays for the
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additional security measures necessary to maintain institutional security.

...

Without these security measures, the risks to institutional security and public safety
would quickly outweigh the benefits of allowing inmate telephone access.”). The
Commission did not adequately account for these costs.
The Order will also deter providers from investing to develop better security
measures because they will have no assurance of a return on that investment. The
resulting blow to security will harm the Correctional Facilities’ ability to protect
the public. The Commission responded that the Order permits providers to include
security costs in setting rates and that providers can seek waivers.

JA__

[Order_¶_53]. But the rate caps prohibit providers from raising rates beyond a
certain level, and the waiver process means only that the Commission holds a veto
over which security features are proper. And, as noted above, the Order says only
that “[s]ecurity features inherent in the ICS providers’ network would . . . likely
constitute recoverable costs.” JA__ [Order_¶_53_n.196] (emphasis added). The
Order thus does not guarantee that such security features may be included in
setting rates—even though, as the record established, costly security features are
necessary to providing inmate calling services while ensuring safety. E.g., JA__
[Epps_Decl._¶_ 6;_Kaemingk_Decl._¶_ 6;_National_Sheriffs’_Ass’n_3/25/2013_
Comment;_South_Dakota_Dep’t_of_Corrections_3/21/2013_Comment].

All of

this reinforces that the Commission is unqualified to measure the trade-offs in

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administering sound correctional policy, and that any of the Commission’s
purported findings regarding those trade-offs are entitled to no deference. See
Gonzales v. Oregon, 546 U.S. 243, 269 (2006).
C.

The Order Conflicts With Record Evidence Establishing That The
Commission’s Rates Are Unreasonably Low.

The record also demonstrates that the Commission’s rate cap is
unreasonably low when compared to non-inmate, interstate collect calling offered
to

the

public.

See,

e.g.,

JA__

[Corrections_Corp._of_America_5/2/2007_Comment_at_9] (explaining that “[t]he
most appropriate evaluation of inmate calling rates . . . would be to compare the
rates charged for calls from correctional facilities with the rates charged for
person-to-person collect calls that are available to the general public”).
The record shows that carriers charge rates for non-inmate interstate collect
calling that far exceed the collect call rate caps set by the Order. See, e.g., JA__
[Corrections_Corp._of_America_5/2/2007_Comment_at 9].

For example, one

carrier charges $0.45 per minute for interstate collect calling,6 while another
charges $0.89 per minute,7 with both carriers imposing additional per-call charges.

6

JA__ [Global_Crossing_Companies,_Domestic_Informational_Price_List_No.
1,_at_204_(effective_Feb._1,_2001),_http://www.level3.com/en/legal/globalcrossing-tariffs/~/media/96EE3A0624F24E50BC1AC03CC6038617.ashx].
7
JA__
[XO_Communications,_Rates_for_Operator_and_Directory_Assistance,_at_1,_htt
p://www.xo.com/uploadedFiles/_Site_Documents/XORates_ChargesDA4.pdf].
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These non-inmate collect calling services do not include expensive security
features, yet they are much more expensive than what the Commission deemed
reasonable for inmates who make the same type of calls with those features. The
Commission ignored this evidence. By setting safe harbors and caps that are
unreasonably low for correctional facilities—especially smaller ones, see supra
Part II-A—the Order “‘runs counter to the evidence’ in the record.”

JA__

[Dissent_at_122] (quoting State Farm, 463 U.S. at 43).
III.

The Order Impermissibly Abrogates Existing Contracts For Inmate
Calling Services.
The Order is also unlawful because it abrogates existing contracts between
8

inmate calling service providers and correctional facilities.

In Regents of University System of Georgia v. Carroll, the Supreme Court
made clear that the Commission lacks authority to abrogate existing contracts. See
338 U.S. 586, 602 (1950) (“[T]he Communications Act [does not] give authority to
the Commission to determine the validity of contracts between licensees and
others.”). Although this Court has described Carroll’s scope as “modest,” it has
recognized that the Commission may not void contracts between licensees and
third parties—like the state and local correctional facilities affected by the Order.
Cellco P’ship v. FCC, 700 F.3d 534, 543 (D.C. Cir. 2012).

8

This Court has

The Commission also disregarded evidence that abrogating existing contracts
disserves the public interest. See Provider Brief, Part V.
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explained that, under Carroll, “the Commission lacks authority to invalidate
licensees’ contracts with third parties,” “to abrogate state-law contract remedies,”
or to otherwise “void third-party contracts.” Id.
The Order defies Carroll and Cellco because it renders nugatory existing
contracts between providers and correctional facilities by effectively prohibiting
the site commissions that many of those contracts demand.

To be sure, the

Commission insisted that the Order does not “directly overrid[e]” these contracts
and that the Order “relate[s] only to the relationship between ICS providers and
end users.” JA__ [Order_¶_100]. That position disregards the reality that the
Order effectively bans site commissions. The Commission recognized as much
when it conceded that the Order would end “some or all” of the programs funded
by site commissions—a result that would occur only if site commissions were no
longer available. JA__ [Order_¶_57]. The Commission also conceded the need
for “renegotiat[ing]” existing contracts or “terminat[ing] existing contracts so they
can be rebid based on revised terms that take into account the Commission’s
requirements” under the Order. JA__ [Order_¶_102]; see JA__ [Order_¶_102]
(“To the extent that any contracts are affected by our reforms, we strongly
encourage parties to work cooperatively to resolve any issues.” (emphasis added)).
But these are just candy-coated admissions that the Order renders unlawful
existing contracts involving third parties:

46

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“renegotiat[e]” or “terminate” existing contracts if correctional facilities could still
insist on site commissions. And, as noted above, some States require commissions
in contracts for inmate calling services.

Existing contracts that contain such

requirements cannot be performed without running afoul of the Order or can be
performed only at a substantial financial loss that no rational provider would
accept. Because the Order conflicts with Carroll and Cellco, it must be vacated.
CONCLUSION
For the foregoing reasons, as well as those given in the Provider Brief, this
Court should vacate the Order.
Respectfully submitted,
/s/ Helgi C. Walker
Helgi C. Walker
Counsel of Record
Scott G. Stewart
Philip S. Alito
GIBSON, DUNN & CRUTCHER LLP
1050 Connecticut Avenue, N.W.
Washington, D.C. 20036
(202) 887-3599
(202) 530-9595 (fax)
HWalker@gibsondunn.com
May 22, 2014

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RULE ECF-3(B) ATTESTATION
In accordance with D.C. Circuit Rule ECF-3(B), I hereby attest that all other
parties on whose behalf this joint brief is submitted concur in the brief’s content.

Respectfully submitted,
/s/ Helgi C. Walker
Helgi C. Walker
Counsel of Record
Scott G. Stewart
Philip S. Alito
GIBSON, DUNN & CRUTCHER LLP
1050 Connecticut Avenue, N.W.
Washington, D.C. 20036
(202) 887-3599
(202) 530-9595 (fax)
HWalker@gibsondunn.com
May 22, 2014

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CERTIFICATE OF COMPLIANCE
Pursuant to Federal Rule of Appellate Procedure 32(a)(7)(C) and D.C.
Circuit Rule 32(a), as modified by the Court’s April 22, 2014 briefing order
granting the Correctional Facility Petitioners and Supporting Intervenors 10,200
words, the undersigned certifies that this brief complies with the applicable typevolume limitations. This brief was prepared using a proportionally spaced type
(Times New Roman, 14 point). Exclusive of the portions exempted by Federal
Rule of Appellate Procedure 32(a)(7)(B)(iii) and D.C. Circuit Rule 32(a)(1), this
brief contains 10,077 words. This certificate was prepared in reliance on the wordcount function of the word-processing system used to prepare this brief.
Respectfully submitted,
/s/ Helgi C. Walker
Helgi C. Walker
Counsel of Record
Scott G. Stewart
Philip S. Alito
GIBSON, DUNN & CRUTCHER LLP
1050 Connecticut Avenue, N.W.
Washington, D.C. 20036
(202) 887-3599
(202) 530-9595 (fax)
HWalker@gibsondunn.com
May 22, 2014

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ADDENDUM OF STATUTORY PROVISIONS

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TABLE OF CONTENTS

5 U.S.C. § 706 ....................................................................................................... A-1
47 U.S.C. § 151 ..................................................................................................... A-2
47 U.S.C. § 201 ..................................................................................................... A-3
47 U.S.C. § 276 ..................................................................................................... A-4
Ariz. Rev. Stat. § 41-1604.03 ............................................................................... A-6
Cal. Penal Code § 4025 ......................................................................................... A-7
Ind. Code § 5-22-23-7 ........................................................................................... A-9
Mass. Gen. Laws ch. 127, § 3 ............................................................................. A-10
Miss. Code § 47-5-23 .......................................................................................... A-11
Miss. Code § 47-5-158 ........................................................................................ A-12
N.H. Rev. Stat. § 30-B:4 ..................................................................................... A-14
Ohio Rev. Code § 5120.132 ................................................................................ A-16
S.C. Code § 24-5-80............................................................................................ A-17
S.D. Codified Laws § 24-1-4 .............................................................................. A-18
Tex. Gov’t Code § 495.027................................................................................. A-19
Va. Code § 53.1-68 ............................................................................................. A-22

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5 U.S.C. § 706
§ 706. Scope of review
To the extent necessary to decision and when presented, the reviewing court
shall decide all relevant questions of law, interpret constitutional and statutory
provisions, and determine the meaning or applicability of the terms of an agency
action. The reviewing court shall—
(1) compel agency action unlawfully withheld or unreasonably delayed;
and
(2) hold unlawful and set aside agency action, findings, and conclusions
found to be—
(A) arbitrary, capricious, an abuse of discretion, or otherwise not in
accordance with law;
(B) contrary to constitutional right, power, privilege, or immunity;
(C) in excess of statutory jurisdiction, authority, or limitations, or
short of statutory right;
(D) without observance of procedure required by law;
(E) unsupported by substantial evidence in a case subject to sections
556 and 557 of this title or otherwise reviewed on the record of an agency
hearing provided by statute; or
(F) unwarranted by the facts to the extent that the facts are subject to
trial de novo by the reviewing court.
In making the foregoing determinations, the court shall review the whole record or
those parts of it cited by a party, and due account shall be taken of the rule of
prejudicial error.

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47 U.S.C. § 151
§ 151. Purposes of chapter; Federal Communications Commission created
For the purpose of regulating interstate and foreign commerce in
communication by wire and radio so as to make available, so far as possible, to all
the people of the United States, without discrimination on the basis of race, color,
religion, national origin, or sex, a rapid, efficient, Nation-wide, and world-wide
wire and radio communication service with adequate facilities at reasonable
charges, for the purpose of the national defense, for the purpose of promoting
safety of life and property through the use of wire and radio communications, and
for the purpose of securing a more effective execution of this policy by centralizing
authority heretofore granted by law to several agencies and by granting additional
authority with respect to interstate and foreign commerce in wire and radio
communication, there is created a commission to be known as the “Federal
Communications Commission”, which shall be constituted as hereinafter provided,
and which shall execute and enforce the provisions of this chapter.

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47 U.S.C. § 201
§ 201. Service and charges
(a) It shall be the duty of every common carrier engaged in interstate or
foreign communication by wire or radio to furnish such communication service
upon reasonable request therefor; and, in accordance with the orders of the
Commission, in cases where the Commission, after opportunity for hearing, finds
such action necessary or desirable in the public interest, to establish physical
connections with other carriers, to establish through routes and charges applicable
thereto and the divisions of such charges, and to establish and provide facilities and
regulations for operating such through routes.
(b) All charges, practices, classifications, and regulations for and in
connection with such communication service, shall be just and reasonable, and any
such charge, practice, classification, or regulation that is unjust or unreasonable is
declared to be unlawful: Provided, That communications by wire or radio subject
to this chapter may be classified into day, night, repeated, unrepeated, letter,
commercial, press, Government, and such other classes as the Commission may
decide to be just and reasonable, and different charges may be made for the
different classes of communications: Provided further, That nothing in this
chapter or in any other provision of law shall be construed to prevent a common
carrier subject to this chapter from entering into or operating under any contract
with any common carrier not subject to this chapter, for the exchange of their
services, if the Commission is of the opinion that such contract is not contrary to
the public interest: Provided further, That nothing in this chapter or in any other
provision of law shall prevent a common carrier subject to this chapter from
furnishing reports of positions of ships at sea to newspapers of general circulation,
either at a nominal charge or without charge, provided the name of such common
carrier is displayed along with such ship position reports. The Commission may
prescribe such rules and regulations as may be necessary in the public interest to
carry out the provisions of this chapter.

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47 U.S.C. § 276
§ 276. Provision of payphone service
(a) Nondiscrimination safeguards
After the effective date of the rules prescribed pursuant to subsection (b) of
this section, any Bell operating company that provides payphone service—
(1) shall not subsidize its payphone service directly or indirectly from its
telephone exchange service operations or its exchange access operations; and
(2) shall not prefer or discriminate in favor of its payphone service.
(b) Regulations
(1) Contents of regulations
In order to promote competition among payphone service providers and
promote the widespread deployment of payphone services to the benefit of the
general public, within 9 months after February 8, 1996, the Commission shall
take all actions necessary (including any reconsideration) to prescribe
regulations that—
(A) establish a per call compensation plan to ensure that all
payphone service providers are fairly compensated for each and every
completed intrastate and interstate call using their payphone, except that
emergency calls and telecommunications relay service calls for hearing
disabled individuals shall not be subject to such compensation;
(B) discontinue the intrastate and interstate carrier access charge
payphone service elements and payments in effect on February 8, 1996,
and all intrastate and interstate payphone subsidies from basic exchange
and exchange access revenues, in favor of a compensation plan as specified
in subparagraph (A);
(C) prescribe a set of nonstructural safeguards for Bell operating
company payphone service to implement the provisions of paragraphs (1)
and (2) of subsection (a) of this section, which safeguards shall, at a
minimum, include the nonstructural safeguards equal to those adopted in
the Computer Inquiry-III (CC Docket No. 90-623) proceeding;

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(D) provide for Bell operating company payphone service providers
to have the same right that independent payphone providers have to
negotiate with the location provider on the location provider's selecting and
contracting with, and, subject to the terms of any agreement with the
location provider, to select and contract with, the carriers that carry
interLATA calls from their payphones, unless the Commission determines
in the rulemaking pursuant to this section that it is not in the public interest;
and
(E) provide for all payphone service providers to have the right to
negotiate with the location provider on the location provider's selecting and
contracting with, and, subject to the terms of any agreement with the
location provider, to select and contract with, the carriers that carry
intraLATA calls from their payphones.
(2) Public interest telephones
In the rulemaking conducted pursuant to paragraph (1), the Commission
shall determine whether public interest payphones, which are provided in the
interest of public health, safety, and welfare, in locations where there would
otherwise not be a payphone, should be maintained, and if so, ensure that such
public interest payphones are supported fairly and equitably.
(3) Existing contracts
Nothing in this section shall affect any existing contracts between
location providers and payphone service providers or interLATA or intraLATA
carriers that are in force and effect as of February 8, 1996.
(c) State preemption
To the extent that any State requirements are inconsistent with the
Commission's regulations, the Commission's regulations on such matters shall
preempt such State requirements.
(d) “Payphone service” defined
As used in this section, the term “payphone service” means the provision of
public or semi-public pay telephones, the provision of inmate telephone service in
correctional institutions, and any ancillary services.

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Ariz. Rev. Stat. § 41-1604.03
§ 41-1604.03. Special services fund; uses; report
A. A special services fund is established in the state department of
corrections. The department shall administer the fund.
B. The director shall transfer five hundred thousand dollars from the special
services fund annually to the department of corrections building renewal fund
established by § 41-797. Any remaining monies in the special services fund,
including the inmate recreation fund, may be used for the following purposes:
1. The benefit, education and welfare of committed offenders, including
the establishment, maintenance, purchase of items for resale and other
necessary expenses of operation of canteens and hobby shops.
2. To pay the costs of a telephonic victim notification system. Revenues
that are generated by the inmate telephone system and the automated public
access program shall be deposited in the special services fund.
C. On or before August 1 of each year, the department shall submit to the
president of the senate and the speaker of the house of representatives a report that
contains a full and complete account of special services fund transactions relating
to the inmate telephone system and the telephonic victim notification system for
the preceding fiscal year.

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Cal. Penal Code § 4025
§ 4025. Store in county jail; authorization; prices; disposition of profit; inmate
welfare fund, deposits, expenditures, reports; stores not under jurisdiction of
sheriff
(a) The sheriff of each county may establish, maintain and operate a store in
connection with the county jail and for this purpose may purchase confectionery,
tobacco and tobacco users' supplies, postage and writing materials, and toilet
articles and supplies and sell these goods, articles, and supplies for cash to inmates
in the jail.
(b) The sale prices of the articles offered for sale at the store shall be fixed
by the sheriff. Any profit shall be deposited in an inmate welfare fund to be kept
in the treasury of the county.
(c) There shall also be deposited in the inmate welfare fund 10 percent of all
gross sales of inmate hobbycraft.
(d) There shall be deposited in the inmate welfare fund any money, refund,
rebate, or commission received from a telephone company or pay telephone
provider when the money, refund, rebate, or commission is attributable to the use
of pay telephones which are primarily used by inmates while incarcerated.
(e) The money and property deposited in the inmate welfare fund shall be
expended by the sheriff primarily for the benefit, education, and welfare of the
inmates confined within the jail. Any funds that are not needed for the welfare of
the inmates may be expended for the maintenance of county jail facilities.
Maintenance of county jail facilities may include, but is not limited to, the salary
and benefits of personnel used in the programs to benefit the inmates, including,
but not limited to, education, drug and alcohol treatment, welfare, library,
accounting, and other programs deemed appropriate by the sheriff. Inmate welfare
funds shall not be used to pay required county expenses of confining inmates in a
local detention system, such as meals, clothing, housing, or medical services or
expenses, except that inmate welfare funds may be used to augment those required
county expenses as determined by the sheriff to be in the best interests of inmates.
An itemized report of these expenditures shall be submitted annually to the board
of supervisors.
(f) The operation of a store within any other county adult detention facility
which is not under the jurisdiction of the sheriff shall be governed by the
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provisions of this section, except that the board of supervisors shall designate the
proper county official to exercise the duties otherwise allocated in this section to
the sheriff.
(g) The operation of a store within any city adult detention facility shall be
governed by the provisions of this section, except that city officials shall assume
the respective duties otherwise outlined in this section for county officials.
(h) The treasurer may, pursuant to Article 1 (commencing with Section
53600), or Article 2 (commencing with Section 53630) of Chapter 4 of Part 1 of
Division 2 of Title 5 of the Government Code, deposit, invest, or reinvest any part
of the inmate welfare fund, in excess of that which the treasurer deems necessary
for immediate use. The interest or increment accruing on these funds shall be
deposited in the inmate welfare fund.
(i) The sheriff may expend money from the inmate welfare fund to provide
indigent inmates, prior to release from the county jail or any other adult detention
facility under the jurisdiction of the sheriff, with essential clothing and
transportation expenses within the county or, at the discretion of the sheriff,
transportation to the inmate's county of residence, if the county is within the state
or within 500 miles from the county of incarceration. This subdivision does not
authorize expenditure of money from the inmate welfare fund for the transfer of
any inmate to the custody of any other law enforcement official or jurisdiction.

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Ind. Code § 5-22-23-7
§ 5-22-23-7. Correctional facilities calling system fund
(a) The correctional facilities calling system fund is established for the
purposes of improving, repairing, rehabilitating, and equipping department of
correction facilities. The fund consists of the following:
(1) Money deposited in the fund under section 5(d) of this chapter.
(2) Money appropriated by the general assembly.
(3) Money received from any other source.
(b) The department of correction shall administer the fund.
(c) The expenses of administering the fund shall be paid from money in the
fund.
(d) Money in the fund may not be spent unless the general assembly includes
a specific line item appropriation in the budget bill or otherwise specifically
appropriates the money in the fund.
(e) The treasurer of state shall invest the money in the fund not currently
needed to meet the obligations of the fund in the same manner as other public
money may be invested.
(f) Money in the fund at the end of a state fiscal year does not revert to the
state general fund.

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Mass. Gen. Laws ch. 127, § 3
§ 3. Money and property of prisoners; records; custody and return;
transmission to court; interest on deposits
They shall keep a record of all money or other property found in possession
of prisoners committed to such institutions, and shall be responsible to the
commonwealth for the safe keeping and delivery of said property to said prisoners
or their order on their discharge or at any time before. The superintendents of
correctional institutions of the commonwealth and the superintendents and keepers
of jails, houses of correction and of all other penal or reformatory institutions shall,
upon receipt of an outstanding victim and witness assessment, transmit to the court
any part or all of the monies earned or received by any inmate and held by the
correctional facility, except monies derived from interest earned upon said deposits
and revenues generated by the sale or purchase of goods or services to persons in
correctional facilities, to satisfy the victim witness assessment ordered by a court
pursuant to section eight of chapter two hundred and fifty-eight B. Any monies
derived from interest earned upon the deposit of such money and revenue
generated by the sale or purchase of goods or services to persons in the
correctional facilities may be expended for the general welfare of all the inmates at
the discretion of the superintendent.

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Miss. Code § 47-5-23
§ 47-5-23. Exclusive management and control; department responsibilities
The department shall be vested with the exclusive responsibility for
management and control of the correctional system, and all properties belonging
thereto, subject only to the limitations of this chapter, and shall be responsible for
the management of affairs of the correctional system and for the proper care,
treatment, feeding, clothing and management of the offenders confined therein.
The commissioner shall have final authority to employ and discharge all
employees of the correctional system, except as otherwise provided by law.

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Miss. Code § 47-5-158
§ 47-5-158. Inmate Welfare Fund
(1) The department is authorized to maintain a bank account which shall be
designated as the Inmate Welfare Fund. All monies now held in a similar fund for
the benefit and welfare of inmates shall be deposited into the Inmate Welfare Fund.
This fund shall be used for the benefit and welfare of inmates in the custody of the
department.
(2) There shall be deposited into the Inmate Welfare Fund interest
previously earned on inmate deposits, all net profits from the operation of inmate
canteens, the annual prison rodeo, performances of the Penitentiary band, interest
earned on the Inmate Welfare Fund and other revenues designated by the
commissioner. All money shall be deposited into the Inmate Welfare Fund as
provided in Section 7-9-21, Mississippi Code of 1972.
(3) All inmate telephone call commissions shall be paid to the department.
Monies in the fund may be expended by the department, upon requisition by the
commissioner or his designee, only for the purposes established in this subsection.
(a) Twenty-five percent (25%) of the inmate telephone call commissions
shall be used to purchase and maintain telecommunication equipment to be
used by the department.
(b) Until July 1, 2008, twenty-five percent (25%) of the inmate
telephone call commissions shall be deposited into the Prison Agricultural
Enterprise Fund. Beginning on July 1, 2008, thirty-five percent (35%) of the
inmate telephone call commissions shall be deposited into the Prison
Agricultural Enterprise Fund. The department may use these funds to
supplement the Prison Agricultural Enterprise Fund created in Section 47-5-66.
(c) Forty percent (40%) of the inmate telephone call commissions shall
be deposited into the Inmate Welfare Fund.
(4) The commissioner may invest in the manner authorized by law any
money in the Inmate Welfare Fund that is not necessary for immediate use, and the
interest earned shall be deposited in the Inmate Welfare Fund.
(5) The Deputy Commissioner for Administration and Finance shall be the
custodian of the Inmate Welfare Fund. He shall establish and implement internal
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accounting controls that comply with generally accepted accounting principles.
The Deputy Commissioner for Administration and Finance shall prepare and issue
quarterly consolidated and individual facility financial statements to the prison
auditor of the Joint Legislative Committee on Performance Evaluation and
Expenditure Review. The deputy commissioner shall prepare an annual report
which shall include a summary of expenditures from the fund by major categories
and by individual facility. This annual report shall be sent to the prison auditor, the
Legislative Budget Office, the Chairman of the Corrections Committee of the
Senate, and the Chairman of the Penitentiary Committee of the House of
Representatives.
(6) A portion of the Inmate Welfare Fund shall be deposited in the
Discharged Offenders Revolving Fund, as created under Section 47-5-155, in
amounts necessary to provide a balance not to exceed One Hundred Thousand
Dollars ($100,000.00) in the Discharged Offenders Revolving Fund, and shall be
used to supplement those amounts paid to discharged, paroled or pardoned
offenders from the department. The superintendent of the Parchman facility shall
establish equitable criteria for the making of supplemental payments which shall
not exceed Two Hundred Dollars ($200.00) for any offender. The supplemental
payments shall be subject to the approval of the commissioner. The State
Treasurer shall not be required to replenish the Discharged Offenders Revolving
Fund for the supplemental payments made to discharged, paroled or pardoned
offenders.
(7) The Inmate Welfare Fund Committee is hereby created and shall be
composed of seven (7) members: The Deputy Commissioner for Community
Corrections, the Deputy Commissioner of Institutions, the Superintendent of the
Parchman facility, the Superintendent of the Rankin County facility, the
Superintendent of the Greene County facility, and two (2) members to be
appointed by the Commissioner of Corrections. The commissioner shall appoint
the chairman of the committee. The committee shall administer and supervise the
operations and expenditures from the Inmate Welfare Fund and shall maintain an
official minute book upon which shall be spread its authorization and approval for
all such expenditures. The committee may promulgate regulations governing the
use and expenditures of the fund.
(8) The Department of Audit shall conduct an annual comprehensive audit of
the Inmate Welfare Fund.

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N.H. Rev. Stat. § 30-B:4
§ 30-B:4. Superintendent; General Duties and Powers.
The superintendent of the county department of corrections, as an agent of
the county commissioners, shall be vested with all of the powers and subject to all
the duties and limitations provided in this and other chapters relative to the
management of county correctional facilities. These shall include, but are not
limited to, the following:
I. The superintendent shall report to the board of county commissioners of
his county and be answerable to it for the efficient and effective operation of
county correctional facilities.
I-a. The superintendent shall manage all operations of the department and
administer and enforce the laws with which the department is charged.
I-b. The superintendent shall have every power enumerated in the laws,
whether granted to the superintendent, the department, or any administrative unit
of the department. In accordance with these provisions, the superintendent shall:
(a) Annually compile a budget which reflects all fiscal matters related to
the operation of the department and each program and activity of the
department.
(b) Exercise general supervisory authority over all department
employees, in accordance with applicable personnel statutes and rules.
I-c. The superintendent shall adopt such reasonable policies and procedures
necessary to carry out the duties of the department consistent with this chapter.
I-d. The superintendent shall not accept, on behalf of the department, any
grants of money without first obtaining the express consent of the board of
commissioners.
II. The superintendent shall, under the supervision of the county
commissioners, have custody of all the inmates confined to those facilities.
III. (a) The superintendent shall, in person or by agent, receive all persons
sent by lawful authority to the county department of corrections and retain them
until they are released by process appropriate under law, except as provided in
subparagraph (b).
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(b) Whenever a person in the custody of the superintendent under
subparagraph (a) is transported to a state court, the sheriff through the sheriffs
deputies and bailiffs shall be responsible for custody and control of such person
during the time period such person is in the courthouse.
IV. The superintendent shall monthly present to the presiding or designated
justice and the clerk of the superior court in the county a certified list of all pretrial
prisoners who are or have been in custody with the times and causes of their
confinements or discharges.
V. The superintendent shall provide each prisoner in his or her custody with
necessary sustenance, clothing, bedding, shelter, and medical care.
VI. The superintendent of the county department of corrections shall cause
to be kept a correct and itemized account of each employed prisoner's earnings and
debits made and incurred on their account, and shall retain the balance of those
earnings in escrow until the prisoner is discharged from the county department of
corrections, whereupon the superintendent shall cause the prisoner to be paid the
amount due and take a receipt.

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Ohio Rev. Code § 5120.132
§ 5120.132. Prison programs fund
(A) There is hereby created in the state treasury the prisoner programs fund.
The director of rehabilitation and correction shall deposit in the fund all moneys
received by the department from commissions on telephone systems and services
provided to prisoners in relation to electronic mail, prisoner trust fund deposits,
and the purchase of music, digital music players, and other electronic devices. The
money in the fund shall be used only to pay for the costs of the following:
(1) The purchase of material, supplies, and equipment used in any library
program, educational program, religious program, recreational program, or prerelease program operated by the department for the benefit of prisoners;
(2) The construction, alteration, repair, or reconstruction of buildings
and structures owned by the department for use in any library program,
educational program, religious program, recreational program, or pre-release
program operated by the department for the benefit of prisoners;
(3) The payment of salary, wages, and other compensation to employees
of the department who are employed in any library program, educational
program, religious program, recreational program, or pre-release program
operated by the department for the benefit of prisoners;
(4) The compensation to vendors that contract with the department for
the provision of services for the benefit of prisoners in any library program,
educational program, religious program, recreational program, or pre-release
program operated by the department;
(5) The payment of prisoner release payments in an appropriate amount
as determined pursuant to rule;
(6) The purchase of other goods and the payment of other services that
are determined, in the discretion of the director, to be goods and services that
may provide additional benefit to prisoners.
(B) The director shall establish rules for the operation of the prisoner
programs fund.

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S.C. Code § 24-5-80
§ 24-5-80. Governing body to furnish certain items and services to all persons
confined in jail.
The governing body of each county in this State shall furnish, at all times,
sufficient food, water, clothing, personal hygiene products, bedding, blankets,
cleaning supplies, and shelter from extreme heat or cold or rain for all persons
confined in a jail and access to medical care.

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S.D. Codified Laws § 24-1-4
§ 24-1-4. Government of penitentiary by Department of Corrections.
The state penitentiary and its ancillary facilities shall be under the direction
and government of the Department of Corrections.

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Tex. Gov’t Code § 495.027
§ 495.027. Inmate Pay Telephone Service.
(a) The board shall request proposals from private vendors for a contract to
provide pay telephone service to eligible inmates confined in facilities operated by
the department. The board may not consider a proposal or award a contract to
provide the service unless under the contract the vendor:
(1) provides for installation, operation, and maintenance of the service
without any cost to the state;
(2) pays the department a commission of not less than 40 percent of the
gross revenue received from the use of any service provided;
(3) provides a system with the capacity to:
(A) compile approved inmate call lists;
(B) verify numbers to be called by inmates, if necessary;
(C) oversee entry of personal identification numbers;
(D) use a biometric identifier of the inmate making the call;
(E) generate reports to department personnel on inmate calling
patterns; and
(F) network all individual facility systems together to allow the same
investigative monitoring from department headquarters that is available at
each facility;
(4) provides on-site monitoring of calling patterns and customizes
technology to provide adequate system security;
(5) provides a fully automated system that does not require a department
operator;
(6) provides for periodic review by the state auditor of documents
maintained by the vendor regarding billing procedures and statements, rate
structures, computed commissions, and service metering;

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(7) ensures that a ratio of not greater than 30 eligible inmates per
communication device is maintained at each facility;
(8) ensures that no charge will be assessed for an uncompleted call and
that the charge for local calls will not be greater than the highest rate for local
calls for inmates in county jails; and
(9) ensures that each eligible inmate or person acting on behalf of an
eligible inmate may prepay for the service.
(b) The board shall award a contract to a single private vendor to install,
operate, and maintain the inmate pay telephone service. The initial term of the
contract may not be less than seven years. The contract must provide the board
with the option of renewing the contract for additional two-year terms.
(c) The department shall transfer 50 percent of all commissions paid to the
department by a vendor under this section to the compensation to victims of crime
fund established by Subchapter B, Chapter 56, Code of Criminal Procedure1, and
the other 50 percent to the credit of the undedicated portion of the general revenue
fund, except that the department shall transfer the first $10 million of the
commissions collected in any given year under a contract awarded under this
section to the compensation to victims of crime fund established by Subchapter B,
Chapter 56, Code of Criminal Procedure. This section does not reduce any
appropriation to the department.
(d) Subject to board approval, the department shall adopt policies governing
the use of the pay telephone service by an inmate confined in a facility operated by
the department, including a policy governing the eligibility of an inmate to use the
service. The policies adopted under this subsection may not unduly restrict calling
patterns or volume and must allow for an average monthly call usage rate of eight
calls, with each call having an average duration of not less than 10 minutes, per
eligible inmate.
(e) The department shall ensure that the inmate is allowed to communicate
only with persons who are on a call list that is preapproved by the department.
Except as provided by Subsection (f), the department shall ensure that all
communications under this section are recorded and preserved for a reasonable

1

Vernon’s Ann. Texas C.C.P. Art. 56.31 et. seq.

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period of time for law enforcement and security purposes. A recording under this
subsection is excepted from disclosure under Chapter 552.
(f) The department shall ensure that no confidential attorney-client
communication is monitored or recorded by the department or any person acting
on the department's behalf and shall provide to the vendor the name and telephone
number of each attorney who represents an inmate to ensure that communication
between the inmate and the attorney is not monitored or recorded.

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Va. Code § 53.1-68
§ 53.1-68. Minimum standards for local correctional facilities, lock-ups and
personnel, health inspections.
A. The Board shall establish minimum standards for the construction,
equipment, administration and operation of local correctional facilities, whether
heretofore or hereafter established. However, no minimum standard shall be
established that includes square footage requirements in excess of accepted
national standards. The Board or its agents shall conduct at least one unannounced
inspection of each local facility annually. However, in those years in which a
certification audit of a facility is performed and the facility is in compliance with
all the standards, the Board may elect to suspend the unannounced inspection
based upon that certification audit and the history of compliance of the facility with
the standards promulgated in accordance with this section, except in any year in
which there is a change in the administration of a local or regional jail. The Board
shall also establish minimum standards for the construction, equipment and
operation of lock-ups, whether heretofore or hereafter established. However, no
minimum standard shall be established that includes square footage requirements
in excess of accepted national standards.
B. Standards concerning sanitation in local correctional facilities and
procedures for enforcing these standards shall be promulgated by the Board with
the advice and guidance of the State Health Commissioner. The Board, in
conjunction with the Board of Health, shall establish a procedure for the conduct of
at least one unannounced annual health inspection by the State Health
Commissioner or his agents of each local correctional facility. The Board and the
State Health Commissioner may authorize such other announced or unannounced
inspections as they consider appropriate.
C. The Department of Criminal Justice Services, in accordance with § 9.1102, shall establish minimum training standards for persons designated to provide
courthouse and courtroom security pursuant to the provisions of § 53.1-120 and for
persons employed as jail officers or custodial officers under the provisions of this
title. The sheriff shall establish minimum performance standards and management
practices to govern the employees for whom the sheriff is responsible.
D. The superintendent of a regional jail or jail farm shall establish minimum
performance standards and management practices to govern the employees for
whom the superintendent is responsible.
A-22

USCA Case #13-1300

Document #1494161

Filed: 05/22/2014

Page 86 of 86

CERTIFICATE OF SERVICE
I hereby certify that, on May 22, 2014, I electronically filed the Joint Brief
for Correctional Facility Petitioners and Supporting Intervenors with the Clerk for
the United States Court of Appeals for the District of Columbia Circuit using the
appellate CM/ECF system. Participants in the case who are registered CM/ECF
users will be served by the appellate CM/ECF system.
I further certify that, on this date, two copies of the foregoing brief were
served by U.S. first class mail on the following:
Donald B. Verrilli, Jr.
Solicitor General of the United States
United States Department of Justice
950 Pennsylvania Avenue, N.W.
Washington, D.C. 20530-0001
Respectfully submitted,
/s/ Helgi C. Walker
Helgi C. Walker
Counsel of Record
Scott G. Stewart
Philip S. Alito
GIBSON, DUNN & CRUTCHER LLP
1050 Connecticut Avenue, N.W.
Washington, D.C. 20036
(202) 887-3599
(202) 530-9595 (fax)
HWalker@gibsondunn.com
May 22, 2014