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
pwright@prisonlegalnews.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