The plaintiff lawyers group, an association of criminal defense lawyers, have standing in their own right and individually to complain of recording of attorney-client telephone calls from the Travis County Jail. They also state a claim under the Fourth Amendment for unreasonable search and seizure because they have a reasonable expectation of privacy in their attorney-client calls. Securus on its website says it doesn’t record attorney-client calls, but the plaintiffs plausibly allege otherwise. Austin Lawyers Guild v. Securus Technologies, 2015 U.S. Dist. LEXIS 178047 (W.D.Tex. Feb. 4, 2015) (USMJ R&R):
D. Constitutional Claims
Defendants contend Plaintiffs fail to state a claim under the Fourth Amendment for unreasonable search and seizure, the Sixth Amendment for ineffective assistance of counsel, and the First, Fifth, and Fourteenth Amendments for denial of access to the courts. Securus further argues it is not liable for any alleged constitutional violations because it is a private entity not acting under color of state law.
1. Unreasonable Searches and Seizures
The Fourth Amendment protects individuals from unreasonable searches and seizures by the government. A “search” extends to the recording of oral statements and conversations. Katz v. United States, 389 U.S. 347, 353 (1967); Berger v. New York, 388 U.S. 41, 51 (1967). The government cannot monitor or record a call without violating the Fourth Amendment if the parties have a reasonable expectation of privacy in their conversation. Katz, 389 U.S. at 351-52. See also United States v. Jones, 132 S. Ct. 945, 950-51 (2012) (indirectly reaffirming Katz). To establish a Fourth Amendment privacy claim, a plaintiff must demonstrate he had an actual, subjective expectation of privacy, and that his expectation of privacy is objectively reasonable. Zaffuto v. City of Hammond, 308 F.3d 485, 488 (5th Cir. 2002) (citing Katz, 389 U.S. at 351-52).
Pretrial detainees and prisoners do not enjoy the same constitutional protections as unincarcerated individuals. See Hudson v. Palmer, 468 U.S. 517, 527 (1984) (inmate has no reasonable expectation of privacy in prison cell); Bell v. Wolfish, 441 U.S. 520, 556 (1979) (constitutional rights of inmates are “limited by the legitimate goals and policies of penal institution”). Again, it is generally acceptable to record and listen to inmate telephone calls. Riviera, 546 U.S. 1023; Lanza, 370 U.S. at 143. However, the question here is whether recording, listening to, and sharing detainees’ confidential attorney—client telephone calls is a violation of the Fourth Amendment.
Defendants argue Plaintiffs’ Fourth Amendment claim fails because attorneys cannot assert the attorney—client privilege, as that privilege is properly held and asserted by the client. See In re Grand Jury Subpoena, 220 F.3d 406, 408 (5th Cir. 2000) (attorney—client privilege is held by client). While the attorney—client privilege is held by the client, the Fourth Amendment reasonable expectation of privacy standard is distinguishable from the pure attorney—client privilege. All parties who have a reasonable expectation of privacy in a conversation are protected by the Fourth Amendment. See Gennusa v. Shoar, 879 F. Supp. 2d 1337, 1348 (M.D. Fla. 2012), aff’d 748 F.3d 1103 (11th Cir. 2014) (local criminal defense attorney and client had reasonable expectation of privacy when communicating with pretrial detainee client in interrogation room when officials led attorney to believe conversations would not be monitored); Lonegan v. Hasty, 436 F. Supp. 2d 419, 435 (E.D.N.Y. 2006) (“Although the privilege afforded to attorney—client communications generally belongs to the client, not to the attorney, see United States v. Goldberger & Dubin, P.C., 935 F.2d 501, 504 (2d Cir. 1991), the existence of robust protections for attorney—client communications makes [attorney-plaintiffs’] expectation of privacy in their conversations with Detainees reasonable.”).
Both attorneys and clients have an objectively reasonable expectation of privacy in confidential communications between an attorney and client. See Upjohn Co. v. United States, 449 U.S. 383 (1981) (attorney—client privilege is the “oldest of the privileges for confidential communications known to the common law”). Fourth Amendment protection thus extends to attorneys engaged in confidential communications with their clients and the expectation of privacy in those communications is objectively reasonable. Therefore, it must be determined whether the attorneys and clients had an actual, subjective expectation of privacy.
Defendants assert Plaintiffs have not alleged a subjective expectation of privacy because Plaintiffs have not alleged the recordings were made without notice. Defendants attempt to analogize the case here to United States v. Novak, 531 F.3d 99 (1st Cir. 2008), wherein the First Circuit held detainees had no reasonable expectation of privacy because they were notified that all calls were being recorded and attorney—client telephone calls were mistakenly recorded. Id. at 101. Plaintiffs allege three facts which distinguish this case from Novak and support their contention that attorneys and detainee clients had an actual, subjective expectation of privacy. First, Plaintiffs allege the Travis County Sheriff’s Office and Securus tell the public attorney—client telephone calls are not recorded. Second, Plaintiffs allege Major Long stated that attorney—client telephone calls are not recorded or listened to by his staff. (First Am. Compl. ¶ 15). Third, Plaintiffs allege “Defendants similarly lead detainees to believe” their attorney—client telephone calls are confidential. Moreover, nowhere in the complaint did Plaintiffs allege detainees or attorneys were notified that their calls were being recorded. Plaintiffs have therefore properly alleged that attorneys and detainee clients have a reasonable expectation of privacy in their confidential communications. Accordingly, this claim should not be dismissed.
"If it was easy, everybody would be doing it. It isn't, and they don't." —Me
"Life is not a matter of holding good cards, but of playing a poor hand well." –Josh Billings (pseudonym of Henry Wheeler Shaw), Josh Billings on Ice, and Other Things (1868) (erroneously attributed to Robert Louis Stevenson, among others)
“I am still learning.” —Domenico Giuntalodi (but misattributed to Michelangelo Buonarroti (common phrase throughout 1500's)).
"Love work; hate mastery over others; and avoid intimacy with the government."
—Shemaya, in the Thalmud
"It is a pleasant world we live in, sir, a very pleasant world. There are bad people in it, Mr. Richard, but if there were no bad people, there would be no good lawyers."
—Charles Dickens, “The Old Curiosity Shop ... With a Frontispiece. From a Painting by Geo. Cattermole, Etc.” 255 (1848)
"A system of law that not only makes certain conduct criminal, but also lays down rules for the conduct of the authorities, often becomes complex in its application to individual cases, and will from time to time produce imperfect results, especially if one's attention is confined to the particular case at bar. Some criminals do go free because of the necessity of keeping government and its servants in their place. That is one of the costs of having and enforcing a Bill of Rights. This country is built on the assumption that the cost is worth paying, and that in the long run we are all both freer and safer if the Constitution is strictly enforced."
—Williams
v. Nix, 700 F. 2d 1164, 1173 (8th Cir. 1983) (Richard Sheppard Arnold,
J.), rev'd Nix v. Williams, 467 US. 431 (1984).
"The criminal goes free, if he must, but it is the law that sets him free. Nothing can destroy a government more quickly than its failure to observe its own laws,
or worse, its disregard of the charter of its own existence." —Mapp
v. Ohio, 367 U.S. 643, 659 (1961).
"Any costs the exclusionary rule are costs imposed directly by the Fourth Amendment."
—Yale Kamisar, 86 Mich.L.Rev. 1, 36 n. 151 (1987).
"There have been powerful hydraulic pressures throughout our history that
bear heavily on the Court to water down constitutional guarantees and give the
police the upper hand. That hydraulic pressure has probably never been greater
than it is today."
— Terry
v. Ohio, 392 U.S. 1, 39 (1968) (Douglas, J., dissenting).
"The great end, for which men entered into society, was to secure their
property."
—Entick
v. Carrington, 19 How.St.Tr. 1029, 1066, 95 Eng. Rep. 807 (C.P. 1765)
"It is a fair summary of history to say that the safeguards of liberty have
frequently been forged in controversies involving not very nice people. And
so, while we are concerned here with a shabby defrauder, we must deal with his
case in the context of what are really the great themes expressed by the Fourth
Amendment."
—United
States v. Rabinowitz, 339 U.S. 56, 69 (1950) (Frankfurter, J., dissenting)
"The course of true law pertaining to searches and seizures, as enunciated
here, has not–to put it mildly–run smooth."
—Chapman
v. United States, 365 U.S. 610, 618 (1961) (Frankfurter, J., concurring).
"A search is a search, even if it happens to disclose nothing but the
bottom of a turntable."
—Arizona
v. Hicks, 480 U.S. 321, 325 (1987)
"For the Fourth Amendment protects people, not places. What a person knowingly
exposes to the public, even in his own home or office, is not a subject of Fourth
Amendment protection. ... But what he seeks to preserve as private, even in
an area accessible to the public, may be constitutionally protected."
—Katz
v. United States, 389 U.S. 347, 351 (1967)
“Experience should teach us to be most on guard to
protect liberty when the Government’s purposes are beneficent. Men born
to freedom are naturally alert to repel invasion of their liberty by evil-minded
rulers. The greatest dangers to liberty lurk in insidious encroachment by men
of zeal, well-meaning but without understanding.”
—United
States v. Olmstead, 277 U.S. 438, 479 (1925) (Brandeis, J., dissenting)
“Liberty—the freedom from unwarranted intrusion by government—is as easily lost through insistent nibbles by government officials who seek to do their jobs too well as by those whose purpose it is to oppress; the piranha can be as deadly as the shark.”
"You can't always get what you want / But if you try sometimes / You just might find / You get what you need." —Mick Jagger & Keith Richards, Let it Bleed (album, 1969)
"In Germany, they first came for the communists,
and I didn't speak up because I wasn't a communist. Then they came for the Jews,
and I didn't speak up because I wasn't a Jew. Then they came for the trade unionists,
and I didn't speak up because I wasn't a trade unionist. Then they came for
the Catholics and I didn't speak up because I wasn't a Catholic. Then they came
for me–and by that time there was nobody left to speak up."
—Martin Niemöller (1945) [he served seven years in a concentration
camp]
“Children grow up thinking the adult world is ordered, rational, fit for purpose. It’s crap. Becoming a man is realising that it’s all rotten. Realising how to celebrate that rottenness, that’s freedom.” – John le Carré, The Night Manager (1993), line by Richard Roper
"The point of the Fourth Amendment, which often is not grasped by zealous officers, is not that it denies law enforcement the support of the usual inferences which reasonable men draw from evidence. Its protection consists in requiring that those inferences be drawn by a neutral and detached magistrate instead of being judged by the officer engaged in the often competitive enterprise of ferreting out crime." —Johnson v. United States, 333 U.S. 10, 13-14 (1948)
The book was dedicated in the first (1982) and sixth (2025) editions to Justin William Hall (1975-2025). He was three when this project started in 1978.