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Securus Technologies v. Chris Christie, NJ, ACLU Amicus Brief, 2017

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P.O. Box 32159
Newark, NJ 07102
Tel: 973-854-1714
Fax: 973-642-6523
ashalom@aclu-nj.org
www.aclu-nj.org

AMERICAN CIVIL LIBERTIES UNION
of NEW JERSEY

June 7, 2017
Honorable Kay Walcott-Henderson, J.S.C.
Superior Court of New Jersey
Law Division, Mercer County
175 South Broad Street
Trenton, New Jersey 08608
Re: Securus Technologies, Inc. v. Christopher Christie,
Governor of New Jersey, et al.
Docket No.: MER-L-143-17
Dear Judge Walcott-Henderson:
Please accept this proposed amici curiae letter brief in
lieu of a more formal brief from proposed amici the American
Civil Liberties Union of New Jersey (ACLU-NJ); The Immigrant
Rights Clinic (IRC) of Washington Square Legal Services, Inc.;
New

Jersey

Advocates

for

Immigrant

Detainees

(NJAID);

First

Friends of New Jersey and New York (First Friends); and the
Prison

Policy

Initiative

(PPI).

The

law

at

issue,

the

Rate

Control Law (RCL), does not implicate Plaintiff’s legal rights.
Additionally, the Legislature acted within its authority when it
restricted usurious or inflated phone rates that reduce inmates’
connections
Securus’

with

the

outside

world.

request

for

injunctive

and

Amici

opposes

declaratory

Plaintiff

relief

and

supports the State’s motion to dismiss Securus’ complaint in
this matter.

TABLE OF CONTENTS
STATEMENT OF FACTS/PROCEDURAL HISTORY...........................2
ARGUMENT........................................................2
I.

THE STATE MAY PROTECT THE PUBLIC INTEREST BY
PREVENTING USURIOUS OR INFLATD PHONE RATES THAT
REDUCE INMATES’ CONTACT WITH THE OUTSIDE WORLD........2

II.

THE RCL HAS NOT DEPRIVED SECURUS OF ITS
PROPERTY INTEREST.....................................6

CONCLUSION......................................................8
STATEMENT OF FACTS AND PROCEDURAL HISTORY
For purposes of this brief, Amici adopts the Statement of
Facts and Procedural History set forth by the State.
ARGUMENT
I. THE STATE MAY PROTECT THE PUBLIC INTEREST BY PREVENTING
USURIOUS OR INFLATED PHONE RATES THAT REDUCE INMATES’
CONTACT WITH THE OUTSIDE WORLD.
The Legislature has a right to regulate business within the
state unless it is otherwise beyond the bounds of its authority.
See,

e.g.,

(declaring

Manigault
“[i]t

is

v.

Springs,

settled

law

199

U.S.

473,

of

this

court

480

(1905)

that

the

interdiction of statutes impairing the obligation of contracts
does not prevent the State from exercising such powers as are
vested

in

it

for

the

promotion

of

the

common

weal,

or

are

necessary for the general good of the public, though contracts
previously

entered

into

between

individuals

may

thereby

be

affected”); see also, Lane Distributors, Inc. v. Tilton, 7 N.J.
349,

362

(1951)(explaining

that
2

the

regulation

of

private

enterprise by a public authority is valid “when done in the
exercise of the police power of the state”). In this case, the
Legislature used its authority to ensure that the profit motives
of

facilities

and

vendors

do

not

grossly

burden

prisoners’

contact with the outside world.
It

is

well

established

that

regular

contact

between

offenders and their families benefits offenders, families and
the public. See, e.g., Linda G. Bell and Connie S. Cromwell,
Evaluation of a Family Wellness Course for Persons in Prison,
45, 46 (2015) (noting numerous studies collectively finding that
family

contact

incarceration

can
on

mitigate

children,

the

negative

increase

the

impact

of

likelihood

parental
of

post-

incarceration family reunification, improve the mental health of
ex-offenders and their families, and reduce recidivism). Yet,
for decades, families across the country and within New Jersey
had been forced to pay exorbitant and frequently prohibitive
phone costs in order to stay connected to their incarcerated
loved

ones.

See,

e.g.,

Drew

Kukorowski,

Peter

Wagner

&

Leah

Sakala, Please Deposit All of Your Money: Kickbacks, Rates, and
Hidden Fees in the Jail Phone Industry, PRISON POLICY INITATIVE,
May

2013,

at

2,

available

at:

https://static.prisonpolicy.org/phones/please_deposit.pdf
(illustrating

that

a

15-minute

call

from

prison

or

jail

frequently “cost[s] more than $17 — a disturbing anomaly in the
era of unlimited long-distance plans for only $52.99 a month.”);
3

Comment on Prison Phone and Video Rates by New Jersey Advocates
for Immigrant Detainees and New York University School of Law
Immigrant Rights Clinic, Public Notice #342689, at 3, available
at:

https://www.fcc.gov/file/11928/download

(charting

Passaic

County’s June 2016 phone rates as $2.55 for the first minute and
$0.25 cents for each additional minute – amounting to $6.05 for
a brief 15-minute call).
Moreover, these excessive rates stem from non-service based
charges, such as facility commissions. See Rates for Interstate
Inmate Calling Services, Report and Order and Further Notice of
Proposed Rulemaking, 28 FCC Rcd 14107, 14110 ¶ 3 (2013)(“2013 ICS
Order”)(“ A significant factor driving these excessive rates is
the widespread use of site commission payments – fees paid by
ICS

providers

corrections

to

in

inmate

correctional

order

to

win

phone

facilities

the

or

exclusive

departments

right

to

provide

available

service”),

of

at:

https://apps.fcc.gov/edocs_public/attachmatch/FCC-13113A1_Rcd.pdf;
Survey
LEGAL

Examines
NEWS

service
accept

see

1,

also

Prison
3

John
Phone

E.

Contracts,

(2011)(finding

kickbacks

average

commissions,

and

in

Dannenberg,

42%

that

in

Kickbacks,
2008

nationwide

some

available

cases

Nationwide

“[p]rison

among

reach

22

states

60%

or

PLN

PRISON
phone
that
more),
at

https://www.prisonlegalnews.org/media/publications/revised%20nat

4

ionwide%20pln%20survey%20examines%20prison%20phone%20contracts%2
C%20kickbacks.pdf.
Since

2012,

the

FCC

has

implemented

several

reforms

to

ensure that prison phone rates are fair, just, and reasonable.
See,

e.g.,

Notice

of

Proposed

Rulemaking,

27

FCC

Rcd

16629

(2012); Rates for Interstate Inmate Calling Services, Report and
Order

and

Further

Notice

of

Proposed

Rulemaking,

28

FCC

Rcd

14107 (2013) (“2013 ICS Order”); Rates for Interstate Calling
Services,

30

Interstate
Order).

In

FCC

Rcd

Inmate
so

12763

Calling

doing,

it

(2015)

(“2015

Services,
has

FCC

Order”);

16-102

recognized

that

Rates

(2016)

for

(“2016

“[m]aintaining

contact with family and friends during incarceration not only
helps the inmate, but it is beneficial to our society as a
whole.”

In

re

Rates

Notice

of

Proposed

for

Interstate

Rulemaking,

Inmate

27

FCC

Calling
Rcd

Services,

16629,

16660

(statement of Comm’r Clyburn).
In 2016, New Jersey joined the national movement for phone
justice and enacted the RCL. The landmark law forbids facilities
from entering contracts with vendors whose rates exceed 11 cents
per

minute

for

international

domestic

calls.

calls

N.J.S.A.

or

25

cents

30:4-8.12(a);

per

minute

N.J.S.A.

for

30:4-

8.12(c). It also precludes facilities from receiving commissions
or surcharges for telephone usage by inmates. N.J.S.A. 30:48.12(b). In so doing, New Jersey took a critical step in ending
grossly exploitative inmate telephone rates.
5

In short, New Jersey had the authority and moral impetus to
prevent

companies

and

correctional

facilities

from

taking

advantage of our most vulnerable populations.
II. THE RCL HAS NOT DEPRIVED SECURUS OF ITS PROPERTY
INTEREST.
Before the RCL was enacted, Securus entered into contracts
to provide exclusive inmate calling services to Cape May County
and Passaic County Jails. Defendant’s Exhibit A [Def.’s Ex. A];
Defendant’s Exhibit B [Def.’s Ex. B]. Each contract promised
both Securus and the counties it served excessive profits at the
expense

of

some

of

New

Jersey’s

poorest

and

most

vulnerable

residents. The Cape May Contract is due to expire in March of
2018. Def’s Ex. A. The Passaic contract expired, renewed and –
since the enactment of RCL - has been extended to a month-tomonth contract that caps phone rates and eliminates facility
commissions. Def’s Ex. B.
In the years since Securus signed those initial contracts,
New Jersey – like some other States around the nation – has
stopped

companies

from

imposing

exorbitant

phone

charges

in

exchange for facility kickbacks. N.J. P.L. 2016, c. 37, S1880
3R, as codified at C. 30:4-8.11 to -8.14. Critically, however,
the

RCL

enactment.

applies
Id.

As

only

to

such,

contracts
RCL

has

Contact whatsoever.

6

not

entered

into

impacted

the

after

its

Cape

May

Furthermore, Securus cannot claim that RCL amounts to a
property

taking

property

its

interest

government
that

of

the

exists

prevents
company

government

does

public

policy.

(1948)

(finding

extended

a

has

not

private
no

exact

Lichter
that

in

v.

Passaic
future

company

contractual
a

taking,

United

contract

no

When

the

contracts.
from

exploiting

right
it

Act

to

merely

States,

Renegotiation

because

334
which

people

exploit,

the

creates

good

U.S.

742,

787

provided

for

recovery by the Government of “excessive profits” realized by
subcontractors producing war-related products did not amount to
a

taking

under

the

Fifth

Amendment).

Critically,

where

government regulations are limited to future contracts, as here,
claims that the government has engaged in a taking fail. Id. at
788. Thus, new agreements between Securus and Passaic County
that occurred after passage of the law (and thereby necessarily
incorporated the law’s restrictions), do not amount to a taking.
For years, both Securus and counties around New Jersey have
made hundreds of thousands of dollars by exploiting New Jersey’s
most vulnerable residents. Securus hoped to continue to profit
richly

even

after

the

contracts

it

signed

had

expired.

The

dashing of that hope does not amount to a taking. Because there
was no taking, the complaint must be dismissed.

7

CONCLUSION
For

all

the

foregoing

reasons,

the

State’s

motion

to

dismiss should be granted.
Respectfully submitted,

________________
_
Iris Bromberg (ID # 067272013)
Alexander Shalom (ID # 021162004)
Edward Barocas
Jeanne LoCicero
AMERICAN CIVIL LIBERTIES UNION OF
NEW JERSEY FOUNDATION
Counsel for Amici

8