HRDC comment on prison visitation rule change in New Jersey
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Human Rights Defense Center DEDICATED TO PROTECTING HUMAN RIGHTS July 3, 2019 Kathleen Cullen Administrative Rules Unit Office of the Commissioner P.O. Box 863 Trenton, New Jersey 08625 Re: Proposal Number: PRN 2019-051 Dear Ms. Cullen, The Human Rights Defense Center (HRDC) is the co-founder of the national Campaign for Prison Phone Justice (prisonphonejustice.org / phonejustice.org), which is committed to reducing barriers to communication between prisoners and their families and support networks. HRDC submits this comment for the administrative record to state our support for the proposed rule, PRN 2019-051, particularly our support of the language which clearly defines the terms inperson contact and in-person non-contact visits to ensure that remote video calling technology cannot be used as a substitute for in-person non-contact visits. The reliance of correctional facilities on remote video calling services has increased significantly since the regulation of interstate inmate calling services (ICS) in February 2014, due partially to changes in technology but more substantially due to revenue-seeking opportunism from ICS providers. 1 Although these calls are described as alternatives to in-person visits for individuals who are located long distances from incarcerated loved ones, the reality of video calls are services that are high-cost and low-quality, and often positioned unfairly by ICS providers as absolute replacements for in-person visits. The Prison Policy Initiative reports that 74% of county jails that implemented video calling either reduced or entirely eliminated in-person visits. 2 The reason for this elimination is to entice more prisoners to use costly video calls. In our monthly magazine Prison Legal News, HRDC has repeatedly reported on this “double-edged sword.” 3 Correctional facilities must therefore take care to guard against incursions on in-person visits. 1 https://www.theguardian.com/us-news/2017/dec/09/skype-for-jailed-video-calls-prisons-replace-in-person-visits https://www.prisonpolicy.org/visitation/report.html 3 https://www.prisonlegalnews.org/news/2014/nov/8/double-edged-sword-video-visitation-claiming-keep-familiestogether-while-furthering-aims-prison-industrial-complex and https://www.prisonlegalnews.org/news/2017/mar/31/video-calling-services-vs-person-visitation 2 P.O. Box 1151 Lake Worth, FL 33460 Phone: 561-360-2523 Fax: 866-735-7136 firstname.lastname@example.org In-person visits strongly correlate with safer prisons and decreased recidivism. 4 Although contact visits are the most beneficial method of visitation in terms of supporting prisoners’ mental health and family connectedness, 5 even in-person non-contact visits have proven to be superior to video calls in terms of the preservation of crucial community support. 6 HRDC maintains that video calls simply are not adequate replacements for in-person visits, and we express our support for the proposed rule change, PRN 2019-051, which proactively ensures that New Jersey prisons will not accept inferior video calling technology as a substitute for in-person visits. Sincerely, Paul Wright, Executive Director, HRDC 4 https://law.yale.edu/system/files/area/center/liman/document/prison_visitation_policies.pdf and https://www.prisonlegalnews.org/news/2014/apr/15/lowering-recidivism-through-family-communication 5 https://slate.com/technology/2018/10/video-visitation-prison-inmates-punishment.html 6 https://www.nbcnews.com/feature/in-plain-sight/prison-visits-go-high-tech-isolation-grows-n313616