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USCA Case #15-1461

Document #1617181

Filed: 06/06/2016

ORAL ARGUMENT NOT YET SCHEDULED

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No. 15-1461 and Consolidated Cases

In the United States Court of Appeals
for the District of Columbia Circuit
—————————————————————
GLOBAL TEL*LINK, ET AL.,
Petitioners,
v.
FEDERAL COMMUNICATIONS COMMISSION, AND
THE UNITED STATES OF AMERICA,
Respondents.
—————————————————————
CENTURYLINK PUBLIC COMMUNICATIONS, ET AL.,
Intervenors.
—————————————————————
On Petition for Review of Final Agency Action
of the Federal Communications Commission
80 Fed. Reg. 79,136 (Dec. 18, 2015)
—————————————————————
BRIEF OF STATE AND LOCAL GOVERNMENT PETITIONERS
—————————————————————
James Bradford Ramsay
General Counsel
Jennifer Murphy
Assistant General Counsel
National Association of Regulatory
Utility Commissioners
1101 Vermont Avenue, N.W., Suite 200
Washington, D.C. 20005
P: (202) 898-2207
E: jramsay@naruc.org

E. Scott Pruitt
Attorney General of Oklahoma
Patrick R. Wyrick
Solicitor General
Mithun Mansinghani
Deputy Solicitor General
Oklahoma Office of the Attorney General
313 NE 21st Street
Oklahoma City, OK 73105
P: (405) 521-3921
E: Mithun.Mansinghani@oag.ok.gov

COUNSEL FOR NATIONAL ASSOCIATION
OF REGULATORY UTILITY COMMISSIONERS COUNSEL FOR THE STATE OF OKLAHOMA

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Danny Honeycutt
Oklahoma County Sheriff’s Office
201 N. Shartel Ave.
Oklahoma City, OK 73102
P: (405) 713-2050
E: sodanhon@okcounty.org

Christopher J. Collins
Collins, Zorn & Wagner
429 NE 50th Street, 2nd Floor
Oklahoma City, OK 73105
P: (405) 524-2070
E: cjc@czwglaw.com

COUNSEL FOR JOHN WHETSEL, SHERIFF
OF OKLAHOMA COUNTY, OKLAHOMA

COUNSEL FOR OKLAHOMA SHERIFFS’
ASSOCIATION

Karla L. Palmer
Hyman, Phelps & McNamara, P.C.
700 13th Street, N.W., Suite 1200
Washington, D.C. 20005
P: (202) 737-5600
E: kpalmer@hpm.com

Mark Brnovich
Attorney General of Arizona
Dominic E. Draye
Deputy Solicitor General
Arizona Office of the Attorney General
1275 West Washington
Phoenix, AZ 85007
P: (602) 542-5025
E: dominic.draye@azag.gov

Tonya J. Bond
Joanne T. Rouse
Plews Shadley Racher & Braun LLP
1346 N. Delaware Street
Indianapolis, IN 46202
P: (317) 637-0781
E: tbond@psrb.com
E: jrouse@psrb.com
COUNSEL FOR THE INDIANA SHERIFFS’
ASSOCIATION, MARION COUNTY
SHERIFF’S OFFICE, AND LAKE COUNTY
SHERIFF’S DEPARTMENT

COUNSEL FOR STATE OF ARIZONA
Leslie Rutledge
Attorney General of Arkansas
Lee Rudofsky
Solicitor General
Arkansas Attorney General
323 Center Street, Suite 200
Little Rock, AR 72201
P: (501) 682-8090
E: lee.rudofsky@arkansasag.gov
COUNSEL FOR STATE OF ARKANSAS

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Gregory F. Zoeller
Attorney General of Indiana
Thomas M. Fisher
Solicitor General
Office of the Indiana Attorney General
302 W. Washington Street
IGC-South, Fifth Floor
Indianapolis, IN 46204
P: (317) 232-6255
E: Tom.Fisher@atg.in.gov

Derek Schmidt
Attorney General of Kansas
Jeffrey A. Chanay
Chief Deputy Attorney General
Kansas Office of the Attorney General
Memorial Hall, 3rd Floor
120 SW 10th Avenue
Topeka, KS 66612-1597
P: (785) 368-8435
E: jeff.chanay@ag.ks.gov

COUNSEL FOR STATE OF INDIANA

COUNSEL FOR STATE OF KANSAS

Jeff Landry
Attorney General of Louisiana
Patricia H. Wilton
Assistant Attorney General
Louisiana Department of Justice
1885 North Third Street
Baton Rouge, LA 70802
P: (225) 326-6006
E: wiltonp@ag.louisiana.gov

Chris Koster
Attorney General of Missouri
J. Andrew Hirth
Deputy General Counsel
Missouri Office of the Attorney General
P.O. Box 899
207 W. High Street
Jefferson City, MO 65102
P: (573) 751-0818
E: andy.hirth@ago.mo.gov

COUNSEL FOR STATE OF LOUISIANA

COUNSEL FOR STATE OF MISSOURI
Adam Paul Laxalt
Attorney General of Nevada
Lawrence VanDyke
Solicitor General
Office of the Nevada Attorney General
100 N. Carson Street
Carson City, NV 89701-4717
P: (775) 684-1100
E: LVanDyke@ag.nv.gov
COUNSEL FOR STATE OF NEVADA

Brad D. Schimel
Attorney General of Wisconsin
Misha Tseytlin
Solicitor General
Daniel P. Lennington
Deputy Solicitor General
Wisconsin Department of Justice
Post Office Box 7857
Madison, WI 53707-7857
P: (608) 267-9323
E: tseytlinm@doj.state.wi.us
COUNSEL FOR STATE OF WISCONSIN

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CERTIFICATE AS TO PARTIES, RULINGS, AND RELATED CASES
Pursuant to Circuit Rule 28(a)(1), the State and Local Government Petitioners
certify as follows:
A.

Parties and Amici
The parties participating in the proceeding below are listed in Appendix B to

the challenged Order. These cases involve the following parties:

1.

Petitioners

No. 15-1461:

Global Tel*Link

No. 15-1498:

Securus Technologies, Inc.

No. 16-1012:

Centurylink Public Communications, Inc.

No. 16-1029:

Telmate, LLC

No. 16-1038:

National Association of Regulatory Utility Commissioners

No. 16-1046:

Pay Tel Communications, Inc.

No. 16-1057:
State of Oklahoma, ex rel. Joseph M. Allbaugh, Interim
Director of the Oklahoma Department of Corrections; John Whetsel, Sheriff
of Oklahoma County, Oklahoma; The Oklahoma Sheriffs’ Association, on
behalf of its members.

2.

Respondents

Federal Communications Commission and the United States of America.

3.

Intervenors and Amici Curiae

No. 15-1461: Intervenor for Petitioners: Centurylink Public Communications, Inc.;
Indiana Sheriff’s Association; Lake County Sheriff’s Department; Marion
County Sheriff’s Office.
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Intervenor for Respondents: Campaign for Prison Phone Justice; Citizens United for
Rehabilitation or Errants; DC Prisoners’ Project of the Washington Lawyers’
Committee for Civil Rights and Urban Affairs; Dedra Emmons; Ulandis Forte;
Human Rights Defense Center; Laurie Lamancusa; Jackie Lucas; Darrell
Nelson; Earl J. Peoples; Ethel Peoples; Prison Policy Initiative; United Church
of Christ, Office of Communication, Inc.; Charles Wade; Network
Communications International Corp.
Amicus Curiae for Respondents: Network Communications International Corp.
(terminated 03/07/2016).
No. 16-1057: Intervenor for Petitioners: State of Arizona; State of Arkansas; State
of Indiana; State of Kansas; State of Louisiana; State of Missouri; State of
Nevada; State of Wisconsin.
B.

Rulings Under Review
These consolidated appeals challenge an Order of the Federal Communications

Commission, In the Matter of Rates for Interstate Inmate Calling Services, “Second Report
and Order and Third Further Notice of Proposed Rulemaking,” 30 FCC Rcd. 12763,
FCC 15-136, WC Dkt. No. 12-375 (released November 5, 2015), published December
18, 2015, at 80 Fed. Reg. 79,136.
C.

Related Cases
The cases consolidated before this Court in this action are Case Nos. 15-1461,

15-1498, 16-1012, 16-1029, 16-1038, 16-1046, and 16-1057. In addition, a prior related
action involves some of the same parties and similar issues: Securus Technologies, Inc v.
FCC, No. 13-1280 and consolidated cases (D.C. Cir.).

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CORPORATE DISCLOSURE STATEMENT
Pursuant to Rule 26.1 of the Federal Rules of Appellate Procedure and Circuit
Rule 26.1, the National Association of Regulatory Utility Commissioners (NARUC)
respectfully submits this disclosure statement. All other petitioners are State or local
government entities and are not required to file a disclosure statement. NARUC is a
quasi-governmental nonprofit organization founded in 1889 and incorporated in the
District of Columbia. NARUC is a “trade association” as that term is defined in
Circuit Rule 26.1(b). NARUC has no parent company. No publicly held company has
any ownership interest in NARUC. NARUC represents those government officials in
the fifty States, the District of Columbia, Puerto Rico, and the Virgin Islands, charged
with the duty of regulating, inter alia, the regulated electric utilities within their
respective borders.
Respectfully submitted,
/s/ James Bradford Ramsay
James Bradford Ramsay
General Counsel
NATIONAL ASSOCIATION OF REGULATORY
UTILITY COMMISSIONERS
1101 Vermont Ave., N.W., Suite 200
Washington, D.C. 20005

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TABLE OF CONTENTS
JURISDICTIONAL STATEMENT .............................................................................................. 1
STATEMENT OF THE ISSUES .................................................................................................. 2
STATUTES AND REGULATIONS ............................................................................................. 2
INTRODUCTION........................................................................................................................ 3
STATEMENT OF THE CASE ..................................................................................................... 5
A. Section 276 of the Telecommunications Act of 1996. ................................. 5
B. Inmate Calling Services. ..................................................................................11
SUMMARY OF THE ARGUMENT ...........................................................................................18
STANDING ................................................................................................................................22
STANDARD OF REVIEW .........................................................................................................23
ARGUMENT ..............................................................................................................................24
I. The Commission lacks authority to regulate intrastate ICS rates as
the Order provides. ...................................................................................................24
A. Section 276 requires the Commission to allow independent
payphone providers to compete with Bell companies by ensuring they
are not undercompensated; it does not provide the FCC with plenary
authority to set intrastate payphone rate caps that it deems “just,
reasonable, and fair” to the consumer. .................................................................24
1.

The statutory text. ................................................................................25

2.

The statutory context and structure. .................................................27

3.

The statute’s history and purpose. .....................................................31

4.

The original intent and understanding. .............................................33

B. This Court owes no deference to the FCC’s interpretation of
Section 276, which is unreasonable and attempts to infringe on State
authority.....................................................................................................................36
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1.

Deference is not owed because any ambiguity in the statute
should be resolved against interpretations that infringe on
State authority to regulate intrastate rates. .......................................37

2.

Deference is not owed because the meaning of the statute
can be discerned after application of traditional tools of
statutory construction. .........................................................................41

3.

Deference is not owed because the Commission’s
interpretation is unreasonable. ...........................................................42

II. The Order is unlawful because the Commission’s refusal to
include the costs of ICS to jails and prisons in its calculations is
arbitrary and capricious. .........................................................................................47
A. Jails and prisons incur substantial costs directly related to the
provision of ICS. ......................................................................................................48
B. The Commission failed to provide a reasoned basis for excluding
all facility-borne costs in its calculation of rate caps. .........................................54
C. Because Section 276 requires the Commission to ensure fair
compensation to payphone service providers for all costs, exclusion of
the cost of site commissions is arbitrary and capricious. ...................................59
CONCLUSION ..........................................................................................................................60

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TABLE OF AUTHORITIES
CASES
Alexander v. Marion Cnty. Sheriff,
891 N.E.2d 87 (Ind. Ct. Appeals 2008) ........................................................................... 14
Am. Bar Ass'n v. F.T.C.,
430 F.3d 457 (D.C. Cir. 2005) ............................................................................................ 39
*Am. Pub. Commc'ns Council v. F.C.C.,
215 F.3d 51 (D.C. Cir. 2000) .................................................................................... 8, 9, 35
Americans for Safe Access v. Drug Enf't Admin.,
706 F.3d 438 (D.C. Cir. 2013) ........................................................................................... 23
APCC Servs., Inc. v. Sprint Commc'ns Co.,
418 F.3d 1238 (D.C. Cir. 2005) ................................................................................... 10, 35
AT & T Corp. v. Iowa Utilities Bd.,
525 U.S. 366 (1999) ..................................................................................................... 5, 6, 39
Bond v. United States,
134 S. Ct. 2077 (2014) ........................................................................................................ 38
Brooks v. United States,
337 U.S. 49 (1949) ............................................................................................................... 27
Brown v. Gardner,
513 U.S. 115 (1994) ............................................................................................................. 41
Bus. Roundtable v. S.E.C.,
647 F.3d 1144 (D.C. Cir. 2011) ......................................................................................... 56
California Indep. Sys. Operator Corp. v. F.E.R.C.,
372 F.3d 395 (D.C. Cir. 2004) ........................................................................................... 42
Chapman v. Houston Welfare Rights Org.,
441 U.S. 600 (1979) ............................................................................................................. 31
(Authorities upon which we chiefly rely are marked with asterisks)
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Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc.,
467 U.S. 837 (1984) ....................................................................................................... 23, 41
Cobell v. Norton,
240 F.3d 1081 (D.C. Cir. 2001) ......................................................................................... 37
Comcast Corp. v. F.C.C.,
579 F.3d 1 (D.C. Cir. 2009) ............................................................................................... 60
Cont'l Air Lines, Inc v. C. A. B.,
519 F.2d 944 (D.C. Cir. 1975) ........................................................................................... 34
Davel Commc'ns, Inc. v. Qwest Corp.,
460 F.3d 1075 (9th Cir. 2006) ........................................................................................... 10
Don't Tear It Down, Inc. v. Pennsylvania Ave. Dev. Corp.,
642 F.2d 527 (D.C. Cir. 1980) ........................................................................................... 42
Ebert v. Poston,
266 U.S. 548 (1925) ............................................................................................................. 33
F.C.C. v. ITT World Commc'ns, Inc.,
466 U.S. 463 (1984) ............................................................................................................... 1
Fin. Planning Ass'n v. S.E.C.,
482 F.3d 481 (D.C. Cir. 2007) ........................................................................................... 32
Florence v. Bd. of Chosen Freeholders,
132 S. Ct. 1510 (2012) ........................................................................................................ 37
Florida Pub. Telecommunications Ass'n, Inc. v. F.C.C.,
54 F.3d 857 (D.C. Cir. 1995) ............................................................................................. 29
*Glob. Crossing Telecommunications, Inc. v. Metrophones
Telecommunications, Inc., 550 U.S. 45 (2007) ............................................ 11, 29, 31, 34
Glob. Crossing Telecommunications, Inc. v. F.C.C.,
259 F.3d 740 (D.C. Cir. 2001) ..................................................................................... 10, 43
Graham Cty. Soil & Water Conservation Dist. v. U.S. ex rel. Wilson,
559 U.S. 280 (2010) ............................................................................................................. 27
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Hearth, Patio & Barbecue Ass'n v. U.S. Dep't of Energy,
706 F.3d 499 (D.C. Cir. 2013) .............................................................................. 36, 41, 42
I.N.S. v. Nat'l Ctr. for Immigrants' Rights, Inc.,
502 U.S. 183 (1991) ............................................................................................................. 27
I.N.S. v. St. Cyr,
533 U.S. 289 (2001) ............................................................................................................. 46
*Illinois Pub. Telecommunications Ass'n v. F.C.C.,
117 F.3d 555 (D.C. Cir. 1997) ....................................................... 5, 6, 7, 9, 32, 34, 35, 39
*Illinois Pub. Telecommunications Ass'n v. F.C.C.,
752 F.3d 1018 (D.C. Cir. 2014) ........................................................................ 6, 10, 11, 32
Insulation Transp. Comm. v. ICC,
683 F.2d 533 (D.C. Cir. 1982) ........................................................................................... 29
*Louisiana Pub. Serv. Comm'n v. F.C.C.,
476 U.S. 355 (1986) ....................................................................................................... 37, 39
Lujan v. Defenders of Wildlife,
504 U.S. 555 (1992) ............................................................................................................. 23
Marbury v. Madison,
5 U.S. 137 (1803) ................................................................................................................. 47
MCI Telecommunications Corp. v. Am. Tel. & Tel. Co.,
512 U.S. 218 (1994) ....................................................................................................... 29, 31
MCI Telecommunications Corp. v. F.C.C.,
143 F.3d 606 (D.C. Cir. 1998) ............................................................................................. 9
Medtronic, Inc. v. Lohr,
518 U.S. 470 (1996) ....................................................................................................... 38, 40
Michigan v. Bay Mills Indian Cmty.,
134 S. Ct. 2024 (2014) ........................................................................................................ 33

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Middle S. Energy, Inc. v. F.E.R.C.,
747 F.2d 763 (D.C. Cir. 1984) ........................................................................................... 34
Morrison v. Nat'l Australia Bank Ltd.,
561 U.S. 247 (2010) ............................................................................................................. 33
Motor Vehicle Mfrs. Ass'n of U.S., Inc. v. State Farm Mut. Auto. Ins. Co.,
463 U.S. 24 (1983) .................................................................................................. 48, 55, 59
NetworkIP, LLC v. F.C.C.,
548 F.3d 116 (D.C. Cir. 2008) ..................................................................................... 11, 32
*New England Pub. Commc'ns Council, Inc. v. F.C.C.,
334 F.3d 69 (D.C. Cir. 2003) ................ 5, 7, 8, 10, 11, 28, 30, 31, 32, 35, 39, 40, 45, 46
O'Lone v. Estate of Shabazz,
482 U.S. 342 (1987) ............................................................................................................. 37
Owner-Operator Ind. Drivers Ass'n, Inc. v. Federal Motor Carrier Safety Admin.,
494 F.3d 188 (D.C. Cir. 2007) ........................................................................................... 55
Republic of Argentina v. Weltover, Inc.,
504 U.S. 607 (1992) ............................................................................................................. 33
Russello v. United States,
464 U.S. 16 (1983) ............................................................................................................... 29
Sec'y of Labor, Mine Safety & Health Admin. v. Excel Mining, LLC,
334 F.3d 1 (D.C. Cir. 2003) ............................................................................................... 34
Shays v. Fed. Election Comm'n,
528 F.3d 914 (D.C. Cir. 2008) ........................................................................................... 29
State of Alaska v. U.S. Dep't of Transp.,
868 F.2d 441 (D.C. Cir. 1989) ........................................................................................... 22
Sw. Bell Tel. Co. v. F.C.C.,
100 F.3d 1004 (D.C. Cir. 1996) ........................................................................................... 6
Torres v. Lynch,
136 S. Ct. 1619 ..................................................................................................................... 47
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Tozzi v. U.S. Dep't of Health & Human Servs.,
271 F.3d 301 (D.C. Cir. 2001) ........................................................................................... 22
Trumpeter Swan Soc. v. E.P.A.,
774 F.3d 1037 (D.C. Cir. 2014) ......................................................................................... 23
U.S. Nat. Bank of Oregon v. Indep. Ins. Agents of Am., Inc.,
508 U.S. 439 (1993) ............................................................................................................. 27
United States v. Am. Trucking Ass'ns,
310 U.S. 534 (1940) ............................................................................................................. 27
United States v. Radio Corp. of Am.,
358 U.S. 334 (1959) ............................................................................................................. 29
Util. Air Regulatory Grp. v. EPA,
134 S. Ct. 2427 (2014) ........................................................................................................ 31
Whitman v. Am. Trucking Associations,
531 U.S. 457 (2001) ............................................................................................................. 31
Yates v. United States,
135 S. Ct. 1074 (2015) ........................................................................................................ 27
STATUTES
5 U.S.C. § 706 ............................................................................................................ 23, 25, 49
28 U.S.C. § 2342 ...................................................................................................................... 1
28 U.S.C. § 2344 ...................................................................................................................... 1
*47 U.S.C. § 152........................................................................................... 24, 30, 39, 40, 41
*47 U.S.C. § 201............................................................ 14, 16, 19, 21, 24, 25, 28-30, 43, 44
47 U.S.C. § 226....................................................................................................................... 46
*47 U.S.C. § 276................................................................ 2-11, 16-21, 24-36, 39-47, 59, 60
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47 U.S.C. § 402......................................................................................................................... 1
Ind. Code §§ 5-22-23-5, -6 ............................................................................................. 14, 37
REGULATIONS
In the Matter of Implementation of the Pay Tel. Reclassification & Comp.
Provisions of the Telecommunications Act of 1996, Report and Order
11 F.C.C. Rcd. 20541 (1996) ............................................................................................... 8
In the Matter of Implementation of the Pay Tel. Reclassification & Comp.
Provisions of the Telecommunications Act of 1996, Order on Reconsideration
11 F.C.C. Rcd. 21233 (1996) ............................................................................................. 35
In re Telecommunications Relay Servs. & the Americans with Disabilities
Act of 1990, 17 F.C.C. Rcd. 21233 (2002) ...................................................................... 30
OTHER AUTHORITIES
BLACK’S LAW DICTIONARY (9th Ed.) ................................................................................. 26
H.R. CONF. REP. 104-458 ............................................................................................. 8, 33
H.R. REP. 104-204............................................................................................................ 8, 33
PHILIP HAMBURGER, IS ADMINISTRATIVE LAW UNLAWFUL? (2014) ............................ 47

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GLOSSARY
Act

The Communications Act of 1934, as amended, 47 U.S.C. §§ 151 et seq.

1996 Act

The Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56

ICS

Inmate Calling Services

Order

The order challenged in this suit, In the Matter of Rates for Interstate Inmate
Calling Services, “Second Report and Order and Third Further Notice of
Proposed Rulemaking,” 30 FCC Rcd. 12763, FCC 15-136, WC Dkt. No.
12-375 (released November 5, 2015)

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JURISDICTIONAL STATEMENT
Petitioners seek review of a Federal Communications Commission (the
“Commission”) final rule published at 80 Fed. Reg. 79,136 (Dec. 18, 2015) (the
“Order”).1 Petitions for review of the Rule were timely filed within 60 days of
publication2 on January 25, 2016 (No. 16-1057, CA10 No. 16-9503) and February 5,
2016 (No. 16-1038), and this Court has jurisdiction to review this agency action under
28 U.S.C. § 2342(1) and 47 U.S.C. § 402(a).3

1

In the Matter of Rates for Interstate Inmate Calling Services, “Second Report and Order and
Third Further Notice of Proposed Rulemaking,” 30 FCC Rcd. 12763, FCC 15-136,
WC Dkt. No. 12-375 (2015) (“Order”), reproduced at Joint Appendix (“J.A.”) __.

2

See 28 U.S.C. § 2344.

3

See also F.C.C. v. ITT World Commc’ns, Inc., 466 U.S. 463, 468 (1984) (“Exclusive
jurisdiction for review of final FCC orders … lies in the Court of Appeals.”).

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STATUTES AND REGULATIONS
Pertinent statutes and regulations are reproduced in the Addendum.

STATEMENT OF THE ISSUES
The Communications Act empowers the Commission to require interstate
phone rates to be “just and reasonable,” but forbids the Commission from any
regulation of intrastate rates. Meanwhile, Section 276 of the Telecommunications Act
of 1996 allows the Commission to promote competition by crafting compensation
plans for payphone providers to ensure that they are “fairly compensated” for each
and every call, including intrastate calls. In the challenged Order, the Commission sets
rate caps for intrastate inmate payphone calls on the premise that it has the authority
to fix intrastate payphone toll and local rates to make them “just, reasonable, and
fair.”
I.

Does the Order exceed the Commission’s statutory authority under
Section 276 because the text, context, history, purpose, and longaccepted meaning of that provision only allows the Commission to
ensure that payphone providers are not undercompensated, and does not
provide the Commission with plenary authority to mandate “just and
reasonable” intrastate local and toll rates akin to the authority provided
for interstate calls by other statutory provisions?

II.

Assuming the Commission has the authority to set intrastate payphone
rate caps, did it do so arbitrarily and capriciously by completely
excluding from its calculations the costs charged to payphone providers
by jails and prisons for the right to provide service in the facility, which
include the costs jails and prisons incur in security measures and other
services related to allowing inmates to place phone calls?
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INTRODUCTION
The Commission Order at issue in this case is a solution in search of statutory
authority. The Commission set out to lower rates charged to inmates for phone calls
made from jails and prisons. What drew the particular ire of the Commission—
because it contributed significantly to the rates—was that state and local government
entities were receiving a portion of the revenue gained from inmate calls and using it
to fund security measures related to the phone calls, as well as other rehabilitative and
inmate welfare programs. Relying on its general authority to require interstate phone
call rates to be “just and reasonable,” the Commission set out strict rate caps for
interstate calls.
But the Commission ran into a few problems. To start, this Court partially
stayed the Commission’s order. More fundamentally, however, most inmate phone
calls are intrastate, not interstate, but the law strictly fenced off the Commission from
requiring intrastate rates to be “just and reasonable” unless unambiguously otherwise
provided, leaving such regulation to the domain of the States. The Commission
eventually decided that the authority on which it would premise its desired public
policy solution was Section 276 of the Telecommunications Act of 1996—a provision
designed to allow independent payphone companies to compete on an equal footing
with the entrenched payphone services of Bell companies by ensuring that the
payphone services are “fairly compensated” for every intrastate and interstate call.
Amalgamating that mandate with its “just and reasonable” authority for interstate calls,
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the Commission decided that it has the authority to set intrastate payphone rates to
the levels it deems “just, reasonable, and fair,” and through that, it could promulgate
its desired intrastate inmate call rate caps.
The Commission’s attempt to cobble together statutory authority to impose
rate caps on intrastate inmate payphone calls, however, flouts almost every applicable
canon of statutory construction. The Commission relies on isolated words in Section
276 while ignoring its text, context, history, purpose, and original meaning, and asks
this Court to defer to its statutory interpretation untethered from any effort to
ascertain Section 276’s actual meaning. But in light of those traditional tools of
statutory construction, Section 276 plainly does not authorize the Commission’s
attempt to limit the compensation that payphone providers, as well as local jails and
State prisons, receive from inmate calling services. Section 276 ensures service
providers are not undercompensated; it does not give the Commission plenary
authority to set intrastate rates to be “just, reasonable, and fair,” nor has this provision
ever been interpreted or applied that way. Instead of deferring to the Commission’s
unreasonable grasp for authority, this Court should invalidate the Order as ultra vires.
To make matters worse, the Commission also arbitrarily ignored the costs to
jails and prisons for allowing access to phone calls in setting its rate caps. For this
additional reason, the Order must be invalidated.

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STATEMENT OF THE CASE
The Commission premises its authority to promulgate the Order in this case on
Section 276 of the Telecommunications Act of 1996.4 A review of the history of
Section 276, as well as the history of the Order, is necessary to understand why the
Order is unlawful.
A.

Section 276 of the Telecommunications Act of 1996.

Because of the high cost of building a telephone network, prior to the mid1980s, “local phone service was thought to be a natural monopoly”; as a result, States
granted exclusive franchises in each locality to local exchange carriers, who owned all
the equipment and provided all the service that make local phone calls possible.5 For
the most part, only carriers “provided payphone service because its provision could
not be accomplished independently from [a carrier’s] network.”6 Due to a 1982
consent decree that divested AT&T from its local carriers, most local carriers were
highly-regulated “Bell operating companies.”7 But advances in technology allowed

4

47 U.S.C. § 276.

5

AT & T Corp. v. Iowa Utilities Bd., 525 U.S. 366, 371 (1999).

6

Illinois Pub. Telecommunications Ass’n v. F.C.C., 117 F.3d 555, 558 (D.C. Cir. 1997),
decision clarified on reh’g, 123 F.3d 693 (D.C. Cir. 1997).

7

New England Pub. Commc’ns Council, Inc. v. F.C.C., 334 F.3d 69, 71 (D.C. Cir. 2003).

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competition with Bell companies to be possible,8 including competition from
independent payphone service providers against the Bells’ payphone operations.9
Despite these technological advances, independent payphones were still not
able to compete on an equal footing with payphone services offered by Bell
companies because (1) Bell companies subsidized their payphone services with the
charges assessed on interexchange carriers10 for long-distance calls;11 (2) independent
payphone providers received no compensation for many “800” number and other
toll-free calls because the fees from those calls went directly to carriers;12 and (3) a Bell
company “could exploit its control over the local phone lines by charging lower
service rates to its own payphones or higher service rates to independent payphone
providers.”13 “It was against this background that the Congress enacted § 276 of the

8

See Iowa Utilities Bd., 525 U.S. at 371.

9

Illinois Pub. Telecommunications Ass’n, 117 F.3d at 558.

10

An interexchange carrier is a carrier that transmits long-distance calls by connecting
customers in two separate local networks operated by local exchange carriers through
the interexchange carrier’s interchange network. See Sw. Bell Tel. Co. v. F.C.C., 100 F.3d
1004, 1005 (D.C. Cir. 1996).

11

Illinois Pub. Telecommunications Ass’n, 117 F.3d at 559.

12

Id.

13

Illinois Pub. Telecommunications Ass’n v. F.C.C., 752 F.3d 1018, 1020 (D.C. Cir. 2014),
cert. denied, 135 S. Ct. 1583 (2015).

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Telecommunications Act of 1996 ‘to promote competition among payphone service
providers.’”14
Section 276 contains two mandates: Bell companies “(1) shall not subsidize its
payphone service directly or indirectly from its telephone exchange service
operations” and they “(2) shall not prefer or discriminate in favor of its payphone
service.”15 It then “directs the Commission to implement section 276(a)’s anti-subsidy
and anti-discrimination mandates by undertaking five specific measures to promote
‘competition among payphone service providers and … the widespread deployment
of payphone services to the benefit of the general public.’”16 One of those five
measures requires the Commission to “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.”17 This provision

14

Illinois Pub. Telecommunications Ass’n, 117 F.3d at 559 (quoting 47 U.S.C. § 276(b)(1)).

15

47 U.S.C. § 276(a).

16

New England Pub. Commc’ns Council, 334 F.3d at 75-76 (quoting 47 U.S.C.
§ 276(b)(1)); see also id. at 71 (“Section 276 of the Act … authorizes the Commission
to prescribe regulations consistent with the goal of promoting competition, requiring
that the Commission take five specific steps toward that goal.”).

17

47 U.S.C. § 276(b)(1)(A).

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specifically “addressed the problem of uncompensated calls,” such as 800 number and
other toll-free calls.18
The 1996 Act’s legislative history confirms this understanding. The report on
the House bill that added the “fairly compensated” directive noted that the provision
was needed because Bell companies were “assured of recovering their payphone
costs,” but independent payphone providers were not.19 Similarly, the conference
report offered as an example ensuring fair compensation for “‘toll-free’ calls to
subscribers to 800 and new 888 services and calls dialed by means of carrier access
codes”—calls for which independent providers were being undercompensated.20
The Commission implemented Congress’s five specified measures to ensure a
level competitive playing field in a comprehensive Order issued in 1996.21 The
Commission first set out to “determine the scope of its new mandate” and, decided
that the directive to ensure that each payphone provider is “fairly compensated for
each and every intrastate and interstate call” required the Commission to act only with

18

Am. Pub. Commc’ns Council v. F.C.C., 215 F.3d 51, 53 (D.C. Cir. 2000).

19

H.R. REP. 104-204, 88 (1995).

20

H.R. CONF. REP. 104-458, 158 (1996).

21

See In the Matter of Implementation of the Pay Tel. Reclassification & Comp. Provisions of the
Telecommunications Act of 1996, Report and Order, 11 F.C.C. Rcd. 20541 (1996) (“First
Payphone Order”); see also New England Pub. Commc’ns Council, 334 F.3d at 71 (“The
Commission implemented section 276 in a series of orders, beginning with the socalled Payphone Orders.”).

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respect to those types of calls for which providers were being undercompensated,
such as 800 number calls.22 The Commission then delineated a series of market-based
reforms to correct for that undercompensation, as well as regulations that
implemented Congress’s four other mandates in Section 276, including those that
prevent Bell subsidization of their payphones and prohibit Bell discrimination against
independent providers in the services the Bell company provides.23
This Court upheld the bulk of those regulations, but invalidated as inadequately
reasoned the per-call compensation rate that carriers were required to pay to
payphone providers for toll-free calls (like 800 number calls).24 The FCC engaged in a
second attempt to set the compensation plan, and this Court again invalidated it as an
unreasoned decision.25 Finally, this Court upheld the FCC’s third attempt to come to a
reasoned decision on this issue.26 In sum, Congress mandated in Section 276(b)(1)(A)
that the FCC institute a compensation plan to enable independent payphone
providers to compete on the same level as Bell payphone services and, “[a]fter several

22

See Illinois Pub. Telecommunications Ass’n, 117 F.3d at 559.

23

See id. at 560-61.

24

See id. at 561-70.

25

See MCI Telecommunications Corp. v. F.C.C., 143 F.3d 606 (D.C. Cir. 1998).

26

See Am. Pub. Commc’ns Council, 215 F.3d at 52.

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failed attempts, the Commission finally crafted such a plan,”27 generally referred to as
the “Payphone Orders.” Subsequent FCC orders and litigation surrounding Section
276 have concerned the specific implementation of the Payphone Orders and
revisions and clarifications.28
But despite the fact that “[t]he FCC and the payphone industry have traveled a
long and winding road in implementing Section 276,”29 the consistent construction of
the provision is that it empowers the FCC “[t]o ensure fair competition in the
payphone market” by ensuring that payphone providers are not undercompensated.30
This Court’s most recent opinion on the “fairly compensated” language confirms that
the “provision responded to the development of long-distance access codes and 800

27

APCC Servs., Inc. v. Sprint Commc’ns Co., 418 F.3d 1238, 1241 (D.C. Cir. 2005), vacated
on other grounds, 550 U.S. 901 (2007).

28

See, e.g., Glob. Crossing Telecommunications, Inc. v. F.C.C., 259 F.3d 740 (D.C. Cir. 2001)
(addressing whether a carrier must compensate a payphone provider after selfcertification of compliance with Payphone Orders); New England Pub. Commc’ns Council,
334 F.3d at 71-73 (addressing Commision order regulating rates Bell companies can
charge payphone providers for use of Bell services); Davel Commc’ns, Inc. v. Qwest Corp.,
460 F.3d 1075 (9th Cir. 2006) (addressing remedy for provider after carrier failed to
file tariffs pursuant to Payphone Orders); Illinois Pub. Telecommunications Ass’n, 752 F.3d
at 1020 (addressing whether refunds to payphone providers were required when Bell
companies violated Payphone Orders); see also Order, Pai dissent at 199-200, J.A.__
(detailing the content of other Commission orders under Section 276).
29

Illinois Pub. Telecommunications Ass’n, 752 F.3d at 1021.

30

Illinois Pub. Telecommunications Ass’n, 752 F.3d at 1020; see also New England Pub.
Commc’ns Council, 334 F.3d at 71.

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numbers that allowed callers to use payphones without depositing coins, thereby
depriving payphone operators of revenue” and the Commission implemented
Section 276 by mandating that “the long-distance carriers who benefited from such
‘dial-around’ calls … compensate payphone providers.”31 By contrast, Section 276 has
never been applied to give the Commission plenary authority to regulate intrastate
payphone rates to the level it deems just and reasonable to the consumer or to ensure
that payphone providers do not receive too much compensation for services in stateregulated markets.32
B.

Inmate Calling Services.

Inmate calling services (ICS) includes typical collect and debit-based payphone
platforms as well as security systems necessary to ensure safety for persons both
inside and outside of the correctional facility.33 ICS programs are a privilege that

31

Illinois Pub. Telecommunications Ass’n, 752 F.3d at 1026; see also Glob. Crossing
Telecommunications, Inc. v. Metrophones Telecommunications, Inc., 550 U.S. 45, 51 (2007)
(stating that “Congress recognized that the ‘free’ call would impose a cost upon the
payphone operator; and it consequently” enacted Section 276(b)(1)(A) to remedy that
problem); NetworkIP, LLC v. F.C.C., 548 F.3d 116, 118 (D.C. Cir. 2008) (noting that
“[t]he concept [of Section 276(b)(1)(A)] is simple: Telecommunications carriers must
compensate [payphone providers] for calls made from payphones,” including for calls
that don’t require the consumer to deposit a coin, such as calls with calling cards);
New England Pub. Commc’ns Council, 334 F.3d at 71.
32

See Order, Pai Dissent at 199-201, J.A.__.

33

Notice of Proposed Rulemaking, Rates for Interstate Inmate Calling Services, 27 FCC
Rcd 16629, ¶¶ 2, 5-6, J.A.__ (Dec. 28, 2012) (2012 NPRM).

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correctional facilities offer so that inmates can communicate with their families in an
attempt to foster a more successful rehabilitation program.
Unlike other payphone services, the phone company cannot provide ICS by
itself; ICS requires a cooperative relationship between provider and facility in order to
safely deliver calling privileges to inmates.34 The service provider’s role is to supply the
calling “platform”—meaning the hardware and software necessary to connect to
telecommunication carriers—as well as the technology and training necessary for
facilities to monitor and record phone calls and the systems to identify inmates and
bill them for their calls. The service provider, however, rarely administers these
measures or facilitates the inmates’ use of the phone.35 Rather, facility employees,
from prison guards to commissary clerks, must securely escort inmates to phones;
monitor and record inmate phone calls to ensure they are not used to further criminal
activity; provide copies of those calls to investigators and prosecutors upon subpoena;
enroll inmates in biometric voice identification systems; maintain, update, and
administer protective do-not-call lists; and enroll inmates into billing systems to
ensure that ICS providers get paid, among other tasks.36 Absent these tasks performed

34

See id. at ¶ 6, J.A.__.

35

See, e.g., Letter from Pay Tel Communications, Inc. to Marlene H. Dortch, Secretary,
FCC, at 3, J.A.__ (filed May 8, 2015).
36

See id. at 9-12.

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by jail and prison officials, allowing inmates unfettered and unsupervised access to
phones would present unacceptable risk to the lives and well-being of both those
inside and outside the prison.37
The services provided by jails and prisons are not free: Correctional facilities
can spend over $100,000 a month to provide ICS privileges to inmates, most of which
goes into the labor hours required to facilitate and monitor inmates’ use of ICS.38
Traditionally, ICS providers would compensate facilities with a portion of the revenue
generated from the tolls charged on inmate phone calls—compensation known as
“location rent” or “site commissions.” In addition to paying for the salaries of the
employees who facilitate ICS programs,39 site commissions are sometimes also used to
fund inmate welfare programs like addiction rehabilitation, inmate education, and
legal research services.40 Those commissions, naturally, increase the costs of providing
calling services and thus ICS rates tend to be higher than normal phone rates.

37

See, e.g., Imperial County Sheriff Jan. 12, 2015 Letter at 2, J.A.__.

38

National Sheriff’s Association Comment, Exhibit A, J.A.__ (Jan. 12, 2015) (listing
ICS-related duties performed by correctional facility employees).

39

See, e.g., Cook County Comment on Second FNPRM, 3-5, J.A.__ (Jan. 12, 2015).

40

See, e.g., Letter from Donny Youngblood, Sheriff, Kern County, California, to
Marlene H. Dortch, Secretary, FCC, at 2, J.A.__ (Jan. 5, 2015).

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Nevertheless, States are active in regulating these rates to ensure that they are
affordable for inmates.41
In 2012, in response to a series of petitions from inmates and their relatives
asking for the Commission to cap interstate ICS rates, the Commission sought
comment on ways to lower those interstate rates to “just and reasonable” levels
pursuant to its authority under Section 201(b) of the Act.42 After the comment period,
the Commission promulgated an Order in its Rates for Interstate Inmate Calling Services
docket (the “2013 Order”), which imposed an interim cap on interstate ICS rates of
$0.21 for prepaid and debit calls and $0.25 for collect calls.43 These caps did not
include facility-borne costs in the rate calculus. The Commission decided that site
commissions “were not part of the cost of providing ICS and therefore [are] not
compensable in interstate ICS rates.”44
A group of ICS providers and industry members challenged the 2013 Order in
this Court, claiming, inter alia, that the rate caps and their calculation were an abuse of

41

See, e.g., Order, Pai dissent at 202, J.A.__; Ind. Code §§ 5-22-23-5, -6 (regulating ICS
rates); Alexander v. Marion Cnty. Sheriff, 891 N.E.2d 87, 96 (Ind. Ct. Appeals 2008)
(holding that sheriff had authority under statute designed to ensure low rates to
receive commission payments pursuant to contract from service providers).

42

2012 NPRM, ¶ 1, J.A.__.

43

Report and Order and Further Notice of Proposed Rulemaking, Rates for Interstate
Inmate Calling Services, 28 FCC Rcd 14107, ¶¶ 59-81, J.A.__ (2013) (“2013 Order”).

44

Id. at ¶ 54, J.A__.

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the Commission’s authority.45 In October 2014, after the 2013 Order was partially
enjoined,46 the Commission issued its Second Further Notice of Proposed Rule Making
(“Second FNPRM”).47 In view of that decision to promulgate new rules, the
Commission asked this Court to hold the litigation over the 2013 Order in abeyance,
and this Court obliged.
Realizing that intrastate calls form the bulk of the ICS market,48 in its Second
FNPRM, the Commission solicited an even broader regulatory scheme than the one
already partially enjoined, and sought comments and data on all facets of ICS,
including intrastate rates, ancillary service fees, costs and functions borne by facilities,
and site commission practices.49 ICS providers and facility operators responded with
comments and data detailing the role that facilities play in ICS provision and the costs

45

See Securus Techs., Inc., v. F.C.C., No. 13-1280 (D.C. Cir.).

46

Id., Order (D.C. Cir. Jan. 13, 2014). Judge Brown would have stayed the entire
Order.

47

See Second Further Notice of Proposed Rulemaking, Rates for Interstate Inmate Calling
Services, 29 FCC Rcd 13170 (2014) (“Second FNPRM”).

48

See 2013 Order, ¶ 131 & n.444, J.A.__.

49

See generally Second FNPRM, J.A.__.

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they incur.50 Comments also informed the Commission that it had no authority to set
intrastate payphone rate caps under Sections 201 and 276.51
In November 2015, the Commission issued its Second Order and Third
FNPRM—the Order at issue in this case. This Order purports to “reform … all
aspects of ICS” by requiring that ICS rates conform with its new interpretation of
Sections 201 and 276—which, according to the Commission, gives it plenary power to
regulate intrastate payphone rates to any level it deems “just, reasonable, and fair”
even if payphone providers are not being undercompensated.52 The regulation
includes, among other mandates, new rate caps for both interstate and—for the first
time—intrastate ICS calls.53 The new caps are tiered based on the size of the
correctional facility, ranging from $0.22 per minute to $0.11 per minute.54 For the
second time, however, the Commission refused to include facility-borne costs and site
commissions in its rate calculus.55 To the Commission, these payments merely “distort

50

See Order, ¶ 18, J.A.__; see also, e.g., National Sheriff’s Association Comment, J.A.__.

51

See, e.g., Nat’l Ass’n of Regulatory Utility Commissioners (NARUC) Comments (Jan.
9, 2015), J.A.__.
52

Order, ¶ 9, J.A.__.

53

Id.

54

Id.

55

See id. at ¶¶ 9, 114-140, J.A.__.

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the ICS marketplace.”56 And while the Commission does not outright prohibit them,
the Commission “otherwise discourage[d]” ICS providers from sharing revenues with
facilities57 and encouraged the States to ban such practices.58
Three Commissioners voted for the Order while two dissented. Commissioner
Pai stated that the Commission lacked the authority under Section 276 to cap
intrastate payphone rates because, given the text and purpose of the provision, and
how it has been invariably applied by the Commission, Section 276 allows for
intrastate rate regulation “only when [they] are too low to ensure fair competition.”59
He also faulted the majority for ignoring the significant and well-documented costs to
jails and prisons of providing ICS.60 Similarly, Commissioner O’Rielly stated that
Section 276 “was not meant to give the Commission the authority to cap end-user
rates” for intrastate payphones and he was “appalled that the Commission would try
to mash together bits and pieces of different provisions in an attempt to create a new
unsubstantiated legal standard: just, reasonable, and fair rates.”61

56

Id. at ¶ 122, J.A.__.

57

Id. at ¶ 9, J.A.__.

58

Id. at ¶ 131, J.A.__.

59

Order, Pai Dissent, at 198-203, J.A.__.

60

Id. at 203-06, J.A.__.

61

Order, O’Rielly Dissent, at 209, J.A.__.

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Petitioners brought the instant action challenging the validity of the Order
before this Court, and this Court again granted a partial stay in its order dated March
23, 2016.
SUMMARY OF THE ARGUMENT
The Order violates the Administrative Procedure Act for two independent
reasons: (I) The Commission’s attempts to limit compensation to payphone providers
by, inter alia, setting intrastate rate caps is in excess of statutory authority, and (II) the
Commission’s refusal to include the costs of ICS to jails and prisons in its rate cap
calculations is arbitrary and capricious.
I.

The Commission premises its authority to set intrastate rate caps on

Section 276(b)(1)(A)’s requirement that that payphone providers are “fairly
compensated” for their services, arguing the provision gives it the authority to set
intrastate rate caps to levels it deems “just, reasonable, and fair.” But Section
276(b)(1)(A) provides the Commission only the limited authority to regulate intrastate
calls to ensure payphone providers are not undercompensated such that they can
compete with the payphone services of Bell companies and other carriers.
Section 276(b)(1)(A) does not provide the Commission with the authority to limit the
compensation given to payphone providers or plenary power to regulate intrastate
payphone rates.
A.

This interpretation of Section 276(b)(1)(A) is compelled by the statute’s

text, context, history, purpose, and contemporaneous interpretation by the
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Commission and courts. The text is focused on payphone compensation and ensuring
competition, rather than on rates or charges more generally or low rates for
consumers. Moreover, the exceptions to the “fair compensation” mandate—such as
for emergency calls—make sense only if the mandate is designed to ensure providers
are not undercompensated rather than also designed to prevent excessive charges.
In enacting Section 276(b)(1)(A), Congress deliberately chose different
language than the well-established, historical, and important “just and reasonable”
authority provided to regulate interstate rates in Section 201(b). This is an unequivocal
indication that Section 276(b)(1)(A) does not provide the Commission the claimed
authority to regulate intrastate payphone rates in the same manner as it regulates
interstate rates. And the rest of Section 276 and the 1996 Act confirm that Congress’s
concern was ensuring competition with Bell companies, not with regulation of
excessive rates.
Section 276’s history and purpose confirm this understanding of the statutory
text. As detailed in the Statement of the Case, through Section 276(b)(1)(A), Congress
intended to correct one of several problems facing independent payphone providers
trying to compete on a level field with Bell companies, namely, the
undercompensation for completing certain calls (e.g., toll-free and 800-number calls).
Congress simply wasn’t trying to fix any issues with payphones making too much
profit or consumers being overcharged for payphone calls.

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Finally, contemporaneous interpretations of Section 276(b)(1)(A) by all three
branches of government show that the original intent and public meaning of the
provision comports with Petitioners’ interpretation. In addition to legislative
committee reports, the Commission itself had always interpreted Section 276(b)(1)(A)
as preventing undercompensation and had always wielded its authority in that way—
and the courts (including this Court) agreed. In fact, the Commission previously
disclaimed the authority to regulate inmate calling compensation levels that were
established pursuant to contract.
B.

Chevron deference is inapplicable in this case because this Court has held

that Section 276 does not confer jurisdiction over intrastate rates unless it is “so
unambiguous or straightforward so as to override” the Act’s directive retaining that
authority exclusively in the States. To the extent that there is any ambiguity in the
statute, both the express terms of the Act and principles of federalism require that the
statute be construed against giving the Commission authority to regulate intrastate
rates. In any event, the meaning of Section 276(b)(1)(A) is clear and the Court need
not consider deference to the Commission before striking down the Order.
And even if Chevron’s second step is reached, this Court must reject the
Commission’s interpretation of Section 276(b)(1)(A) because, in light of the wellestablished tools of statutory construction, it is patently unreasonable. The
Commission made no effort to attempt to construe the statute or apply any canons of
interpretation, but instead directly contradicted an important canon by rendering
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meaningless Congress’s decision to use different words in Sections 201(b) and
Section 276(b)(1)(A). The Commission’s interpretation is also unreasonable because it
attempts to use a statute that was intended to ensure adequate compensation of
payphone providers to deliberately undercompensate providers for costs actually
incurred in the provision of payphone service.
II.

The Commission’s Order is also arbitrary and capricious. Despite

copious record evidence that jails and prisons incur substantial security and support
costs as a direct result of allowing ICS in their facilities—costs which are charged to
the ICS provider—the Commission arbitrarily decided to exclude such costs in its
calculation of the rate caps as not “legitimate.” None of the Commission’s
explanations for wholesale exclusion of such costs amounts to reasoned
decisionmaking.
Mere uncertainty with the data quantifying those costs does not justify
complete abrogation of the duty to consider such costs. Nor does the Commission’s
fallback that the rate caps are sufficiently “generous” to cover those costs withstand
scrutiny because (1) the rate caps were based on average ICS costs that necessarily
means that half of the facilities will not be able to cover their costs; (2) the
Commission’s decision to depart from its “averaging” philosophy by assuming the
lowest facility-cost estimate had no justification and ignores the substantial variation
in facility security requirements (and therefore costs); and (3) in other parts of the
Order, the Commission provides the same excuse for not considering other costs,
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double-counting the purported “cushion” that excuses willful blindness to the cost of
providing ICS.
For these reasons, the Order must be vacated.
STANDING
The Government Petitioners will be directly injured by the Order if it is
enforced. The intention and effect of the Order is to limit the site commissions and
other fees charged by the Government Petitioners,62 thus decreasing revenues by
millions per year and undermining Petitioners’ correctional and rehabilitative
programs, as well as their ability to recoup the costs of providing vital security
measures for ICS.63
These injuries are sufficient to establish the Government Petitioners’
standing.64 Moreover, because the Rule seeks to infringe on State authority to regulate
intrastate rates and to override State contracts, contract laws, and laws regulating ICS
rates,65 the Petitioner States are harmed as sovereigns with the power to create and
enforce law.66 This Court “need only find one party with standing” in order “to

62

Order, ¶¶ 9, 14, 117-44.

63

See Affidavits in attached Addendum, A5-25.

64

See Tozzi v. U.S. Dep’t of Health & Human Servs., 271 F.3d 301, 308-09 (D.C. Cir.
2001).

65

See Argument Section I.B.1, infra.

66

See State of Alaska v. U.S. Dep’t of Transp., 868 F.2d 441, 443-44 (D.C. Cir. 1989).
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proceed to the merits of their claims.”67 Thus, the Government Petitioners have
standing because they will be injured, those injuries will be caused by the FCC’s action
challenged in this case, and vacatur of the FCC’s Rule will redress those injuries.68
STANDARD OF REVIEW
This Court generally considers questions of law de novo.69 However, in certain
circumstances, this Court will defer to an agency’s interpretation of the statute it
administers if the provision is ambiguous as to the question at issue and the agency’s
interpretation is reasonable.70 Nevertheless, as Petitioners argue below, such deference
is not warranted in this case.71 Finally, the Administrative Procedure Act requires
courts to “hold unlawful and set aside agency action, findings, and conclusions found
to be arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with
law.”72

67

Americans for Safe Access v. Drug Enf’t Admin., 706 F.3d 438, 443 (D.C. Cir. 2013).

68

See Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-61 (1992).

69

See Trumpeter Swan Soc. v. E.P.A., 774 F.3d 1037, 1042 (D.C. Cir. 2014) .

70

See Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837, 842-43
(1984).

71

See Argument Section I.B., infra.

72

5 U.S.C. § 706(2)(A).

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ARGUMENT
I.

The Commission lacks authority to regulate intrastate ICS rates as the
Order provides.
A.

Section 276 requires the Commission to allow independent
payphone providers to compete with Bell companies by ensuring
they are not undercompensated; it does not provide the FCC with
plenary authority to set intrastate payphone rate caps that it deems
“just, reasonable, and fair” to the consumer.

In Section 201(b) of the Act, Congress authorized the Commission to carry out
its command that, with respect to interstate telephone communication, “[a]ll charges
[and] practices … shall be just and reasonable.”73 Congress has generally reserved that
same authority with respect to intrastate rates, however, to the States in Section
152(b).74 Separately, in Section 276(b)(1), Congress provided the Commission the
authority to, “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” in order to “promote competition among
payphone service providers.”75
The Commission interprets these provisions to mean that they have the
authority to regulate all intrastate payphone calls to ensure that they are “just,

73

47 U.S.C. § 201(b).

74

See 47 U.S.C. § 152(b).

75

47 U.S.C. § 276(b)(1).

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reasonable, and fair” to the consumer.76 Pursuant to that claimed authority, the
challenged Order set caps on inmate payphone calling rates.
But the text, context, history, purpose, and original understanding of Section
276(b)(1)(A) all confirm that it provides the Commission with only the authority to
ensure that independent payphone service providers, including ICS providers, receive
sufficient compensation for all costs to be competitive with payphone services
provided by Bell companies and other carriers. Once that level of compensation is
reached, and providers are not undercompensated, the Commission’s authority with
respect to intrastate payphone rates is at an end. Section 276(b)(1)(A) does not provide
the Commission with plenary authority to, commensurate with its power under
Section 201, regulate intrastate payphone rates for any purpose to ensure that they are
“just and reasonable.” Accordingly, this Court should “hold unlawful and set aside”
the Commission’s Order because it is “in excess of statutory jurisdiction, authority,
[and] limitations,” and is “short of statutory right.”77
1.

The statutory text.

Section 276(b)(1) begins with giving the Commission only the power to
prescribe regulations that are aimed at “promot[ing] competition among payphone

76

See Order, ¶¶ 3, 48, 57-59, 105-15.

77

5 U.S.C. § 706.

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service providers and promot[ing] the widespread deployment of payphone
services.”78 It is in furtherance of those specific goals that the Commission must
“ensure that all payphone service providers are fairly compensated.”79 The statute’s
concern with providers’ compensation rather than rates or charges more generally
indicate that the provision is focused on ensuring remuneration for payphone
providers, as opposed to the overall justness of the rates for consumers.80 When the
prefatory language expressing the law’s purpose is considered, it becomes more
evident that the Commission’s authority is limited to ensuring providers are not so
undercompensated as to be unable to compete, rather than a broad concern that
payphone rates be equitable for any and all purposes or that payphone providers don’t
receive too much revenue.
This interpretation is confirmed by the exception embedded in Section
276(b)(1)(A): the Commission’s compensation mandate applies to all calls “except that
emergency calls and telecommunications relay service calls for hearing disabled
individuals shall not be subject to such compensation.”81 This exception for calls that

78

47 U.S.C. § 276(b)(1).

79

Id. at § 276(b)(1)(A).

80

See BLACK’S LAW DICTIONARY 322 (9th Ed.) (defining “compensation” as
“Remuneration and other benefits received in return for services rendered; esp., salary
or wages”).
81

47 U.S.C. § 276(b)(1)(A).

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serve immensely important public policies makes perfect sense if Section 276(b)(1)(A)
is only concerned with undercompensation, because Congress could reasonably make
the judgment that payphone providers should be required to complete these calls even
if undercompensated. By contrast, this exception would be absurd if Section(b)(1)(A)
was actually intended to also prevent overcompensation, because it would mean that
the law prohibits exorbitant rates as to all calls except for the calls that matter the most,
such as emergency calls.82
2.

The statutory context and structure.

This construction is confirmed by the immediate statutory context of Section
276.83 The statutory Part that contains Section 276 is titled “Special Provisions
Concerning Bell Operating Companies.”84 Subsection (a) of Section 276 prohibits

82

See Brooks v. United States, 337 U.S. 49, 51 (1949) (holding that the exceptions to a
statute make plain the scope and meaning of the general rule); see also Yates v. United
States, 135 S. Ct. 1074, 1085 (2015) (canon of noscitur a sociis requires courts to “avoid
ascribing to one word a meaning so broad that it is inconsistent with its accompanying
words, thus giving unintended breadth to the Acts of Congress”).

83

See Graham Cty. Soil & Water Conservation Dist. v. U.S. ex rel. Wilson, 559 U.S. 280, 290
(2010) (“Courts have a duty to construe statutes, not isolated provisions.”); U.S. Nat.
Bank of Oregon v. Indep. Ins. Agents of Am., Inc., 508 U.S. 439, 455 (1993) (“[W]e must
not be guided by a single sentence or member of a sentence, but look to the
provisions of the whole law….”); United States v. Am. Trucking Ass’ns, 310 U.S. 534,
543-44 (1940).

84

47 U.S.C. Chp. 5, Subchapter II, Part III. “[T]he title of a statute or section can aid
in resolving an ambiguity in the legislation’s text.” I.N.S. v. Nat'l Ctr. for Immigrants’
Rights, Inc., 502 U.S. 183, 189 (1991).

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unfair subsidization or discriminatory practices of Bell operating companies in favor
of their own payphone services, and this Court has held that subparagraph (b)(1)(A) is
one of five specific measures intended to implement subsection (a)’s mandate.85 Thus,
Section 276(b)(1)(A) is concerned with ensuring that all payphone providers receive
sufficient compensation such that independent providers can compete on a level field
with Bell providers. It has nothing to do with independent payphone providers
systemically receiving “too much” compensation from consumers, since that would
only serve to encourage competitive entry into the market. By contrast, as
Commissioner Pai points out, the Order’s rate caps very well might flout the purposes
of Section 276 by decreasing competition.86
More importantly, the broader statutory context of the Communications Act of
1934 precludes the Commission’s interpretation of Section 276. The Commission’s
position is that its authority to regulate intrastate payphone rates under Section 276 is
commensurate with its authority to regulate interstate rates under Section 201. That
position is belied by the fact that Congress specifically chose to use very different
language in those two sections. “[W]hen Congress uses different language in different

85

New England Pub. Commc’ns Council, 334 F.3d at 75-76.

86

Order, Pai dissent at 206, J.A.__.

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sections of a statute, it does so intentionally.”87 In contrast to the language of Section
276, Section 201(b) mandates that all “charges, practices, classifications, and
regulations” for interstate communications by wire or radio “shall be just and
reasonable.”88 This language was well-established for many decades and was the
subject of countless regulations and judicial rulings at the time of the enactment of
Section 276. In enacting Section 201, Congress gave the Commission broad regulatory
authority over interstate communications in a “traditional form” mirroring regulation
of railroads and public utilities, enabling it to set rates to allow a monopolistic utility
to recover a reasonable profit but also protect the consumer from unjustly high
prices.89 The regulation of rates as “just and reasonable” forms “the heart of the
common-carrier section of the Communications Act,”90 and as a result, interstate
communications are subject to “extensive controls.”91

87

Florida Pub. Telecommunications Ass’n, Inc. v. F.C.C., 54 F.3d 857, 860 (D.C. Cir. 1995)
(citing Russello v. United States, 464 U.S. 16, 23 (1983)); see also Shays v. Fed. Election
Comm’n, 528 F.3d 914, 934 (D.C. Cir. 2008); Insulation Transp. Comm. v. ICC, 683 F.2d
533, 537 (D.C. Cir. 1982).

88

47 U.S.C. § 201(b).

89

Glob. Crossing Telecommunications, Inc., 550 U.S. at 48-49.

90

MCI Telecommunications Corp. v. Am. Tel. & Tel. Co., 512 U.S. 218, 229-30 (1994)

91

United States v. Radio Corp. of Am., 358 U.S. 334, 349 & n.17 (1959).

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If Congress wanted to give the Commission the same authority over intrastate
payphone calls that it has over interstate calls, it knew very well how to do so.92
Instead, unlike Section 201, Section 276(b)(1)(A) requires regulation only to advance
specific statutory purposes and chose the “fairly compensated” language over the
well-worn phrase “just and reasonable” to indicate, as explained above, that the
Commission’s authority was limited to ensuring only that payphone providers were
not undercompensated. Thus, the Commission has previously stated that it “does not
regulate payphone rates.”93
Moreover, Section 276(b)(1)(A) is just one of five statutory subparagraphs,
within a paragraph, within a subsection tailored to make specific reforms in the
payphone market;94 it is not the generalized grant of authority akin to Section 201 that
the Commission asserts. The notion that Section 276(b)(1)(A) completely abrogates
Section 152(b)’s jurisdictional bar on the Commission’s authority over intrastate rates
with respect to a significant portion of the market—payphone calls—does not

92

See Order, Pai dissent at 201, J.A.__ (detailing the differences between Congress’s
language in §§ 201-205 and § 276).
93

In the Matter of Telecommunications Relay Servs. & the Americans with Disabilities Act of
1990, Fifth Report and Order, 17 F.C.C. Rcd. 21233, 21244, ¶ 24 (2002).

94

See New England Pub. Commc’ns Council, 334 F.3d at 71, 75-76.

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withstand scrutiny. There is simply no indication that Congress intended to hide that
elephant in this mousehole.95
3.

The statute’s history and purpose.

As extensively detailed above in Section A of the Statement of the Case, the
history leading up to the enactment of Section 276 and the purposes of its
provisions96 show beyond a doubt that Section 276(b)(1)(A) was intended to address
the undercompensation of independent payphone service providers. Section 276 was
enacted in response to the lack of competition in the payphone market, and
subparagraph (b)(1)(A) specifically addressed one cause of that lack of competition:

95

See Whitman v. Am. Trucking Associations, 531 U.S. 457, 468 (2001) (“Congress, we
have held, does not alter the fundamental details of a regulatory scheme in vague
terms or ancillary provisions—it does not, one might say, hide elephants in
mouseholes.”) (citing MCI Telecommunications Corp., 512 U.S. at 231 (rejecting FCC’s
claimed authority to alter “just and reasonable” rate regulation through ancillary
modification provision)); see also Util. Air Regulatory Grp. v. EPA, 134 S. Ct. 2427, 2444
(2014) (treating such agency claims with “skepticism”).

96

See Chapman v. Houston Welfare Rights Org., 441 U.S. 600, 608 (1979) (“As in all cases
of statutory construction, our task is to interpret the words of these statutes in light of
the purposes Congress sought to serve.”); New England Pub. Commc’ns Council, 334 F.3d
at 77 (interpreting Section 276 based on the statute’s “structure and purpose”); see also
Glob. Crossing Telecommunications, 550 U.S. at 53 (interpreting Communications Act
based on the history of the statutory sections).

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The undercompensation of payphone providers for certain calls (such as toll-free 800
number calls).97
Once the Commission has ensured that this problem was addressed—that
every completed payphone call resulted in sufficient compensation for payphone
providers to enable them to compete—Congress’s purposes have been fulfilled and
Section 276(b)(1)(A) provides no additional authority to the Commission. Nothing in
the history of the enactment of Section 276(b)(1)(A) indicates that Congress was
concerned with overly high phone rates for inmates or payphone customers more
generally. The Commission’s attempt to regulate ICS using Section 276(b)(1)(A)
because it deems the rates too high is simply an attempt to misuse a statutory tool for
a purpose for which it was never intended and to solve an alleged problem the statute
was never meant to address.98 The Order takes a provision intended as a shield to
protect and promote payphone providers and transforms it into a sword to curtail
them. Even if high ICS rates are a problem, it simply is not a problem addressed by

97

See Glob. Crossing Telecommunications, 550 U.S. at 51; Illinois Pub. Telecommunications
Ass’n, 752 F.3d at 1020, 1026; NetworkIP, 548 F.3d at 118; New England Pub. Commc’ns
Council, 334 F.3d at 71, 75-76; Illinois Pub. Telecommunications Ass’n, 117 F.3d at 559.

98

See Fin. Planning Ass’n v. S.E.C., 482 F.3d 481, 487 (D.C. Cir. 2007) (“[U]nder
Chevron’s first step, ‘the court looks to … the problem Congress sought to solve.’”
(citation omitted)).

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Section 276, and “[a] casus omissus does not justify judicial legislation.”99 “It is [the
court’s] function to give the statute the effect its language suggests, however modest
that may be; not to extend it to admirable purposes it might be used to achieve.”100
4.

The original intent and understanding.

When Section 276(b)(1)(A) was enacted and in the time immediately thereafter,
the drafters and those reading the law—namely, the Commission and the Courts—all
agreed that it was intended to address undercompensation of payphone providers. As
recounted in Section A of the Statement of the Case above, the legislative history
indicates that this was the intent of the provision.101 Conversely, no legislator or
committee appears to have ever understood Section 276(b)(1)(A) to mandate that the
Commission exercise the authority it now attempts to wield, namely, the regulation of

99

Ebert v. Poston, 266 U.S. 548, 554 (1925); see also Republic of Argentina v. Weltover, Inc.,
504 U.S. 607, 618 (1992) (“The question, however, is not what Congress ‘would have
wanted’ but what Congress enacted.”). High ICS rates are not even a new problem, as
the Commission admits. Order, ¶ 118 n.375, ¶ 129 n.442, J.A.__, __ (noting that ICS
rates have been high since the late-1980s).

100

Morrison v. Nat’l Australia Bank Ltd., 561 U.S. 247, 270 (2010); see also Michigan v. Bay
Mills Indian Cmty., 134 S. Ct. 2024, 2033-34 (2014) (Courts will not alter meaning of a
statute “just because the text as written creates an apparent anomaly as to some
subject it does not address. … Congress typically legislates by parts—addressing one
thing without examining all others that might merit comparable treatment. …
‘Congress wrote the statute it wrote’—meaning, a statute going so far and no further.”
(citation omitted)).
101

See H.R. REP. 104-204, 88 (1995); H.R. CONF. REP. 104-458, 158 (1996).

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all payphone calling rates because they provide payphones with too much
compensation.
The same is true of the original public meaning of Section 276(b)(1)(A) as
shown by the Commission’s regulations attempting to implement Section 276 and
courts’ interpretation of that provision.102 As discussed in more detail in the Statement
of the Case, the Commission originally interpreted Section 276(b)(1)(A) to provide it
limited authority to regulate rates only for those types of calls for which payphone
providers were not being fairly compensated, and the calls regulated by the
Commission in its orders implementing Section 276 were calls for which providers
were being undercompensated.103 Since then, it has never attempted to use or interpret

102

See Glob. Crossing Telecommunications, 550 U.S. at 48 (noting that “regulatory history
helps to illuminate the proper interpretation and application” of Communication Act
provisions); Sec’y of Labor, Mine Safety & Health Admin. v. Excel Mining, LLC, 334 F.3d
1, 7 (D.C. Cir. 2003) (taking into account the agency’s “original interpretation,
adopted at a time when the origins of both the statute and the finding were fresh in
the minds of their administrators” and giving “weight to the fact that the agency …
interpreted them the same way for more than 25 years”); Middle S. Energy, Inc. v.
F.E.R.C., 747 F.2d 763, 769 (D.C. Cir. 1984) (holding that “the most nearly
contemporaneous construction” of the statute by the agency corroborated the
agency’s lack of authority because the agency disclaimed that authority “in its first
comprehensive discussion of” the provision at issue); see also id. (“Courts regard with
particular respect the contemporaneous construction of a statute by those initially
charged with its enforcement.”); Cont’l Air Lines, Inc v. C. A. B., 519 F.2d 944, 954-55
(D.C. Cir. 1975).

103

See Illinois Pub. Telecommunications Ass’n, 117 F.3d at 559; see also Order, O’Rielly
dissent at 209, J.A.__ (“For those people actually involved, we remember that the
provision was clearly designed to protect payphone providers that had been unable to
(Cont'd on next page)

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Section 276 to limit the compensation payphone providers receive on the market.104
In fact, contrary to the Commission’s current attempts to override state and local
government contracts with ICS providers, the Commission in 1996 rejected a request
to regulate inmate calling rates, concluding that “whenever a [provider] is able to
negotiate for itself the terms of compensation for the calls its payphones originate,
then our statutory obligation to provide fair compensation is satisfied.”105
This Court too recognized that this was the proper course for the Commission
to take to fully implement Section 276(b)(1)(A),106 noting that the law requires the
Commission to create a compensation plan, and that the “Payphone Orders”
correcting the systematic undercompensation meant “the Commission finally crafted
such a plan.”107 Nothing in this Court’s decisions addressing the Commission’s

(Cont'd from previous page)

receive fair compensation for their service from [carriers]. It was not meant to give
the Commission authority to cap end-user rates.”).
104

See Order, Pai Dissent at 199-201, J.A.__.

105

In the Matter of Implementation of the Pay Tel. Reclassification & Comp. Provisions of the
Telecommunications Act of 1996, Order on Reconsideration, 11 F.C.C. Rcd. 21233, ¶ 72
(1996); see also id. at ¶ 52 (ruling that “[t]he level of 0+ commissions paid pursuant to
contract on operator service calls is beyond the scope of [] Section 276”).
106

New England Pub. Commc’ns Council, 334 F.3d at 71, 75-76; Am. Pub. Commc’ns
Council, 215 F.3d at 53; Illinois Pub. Telecommunications Ass’n, 117 F.3d at 559.

107

APCC Servs., Inc., 418 F.3d at 1241; see also Order, Pai dissent at 199, J.A.__ (“The
FCC prescribed regulations to fulfill [the duties created by Section 276] before the end
of 1996.”).
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implementation of Section 276 even contemplated that the Commission’s orders
failed to complete the task mandated by Congress on account of the orders not
protecting against unfairly high charges by payphone providers to consumers, inmates
or otherwise.108
*

*

*

When the work of statutory construction is done, it is obvious that Section 276
unambiguously does not give the Commission the authority it purports to exert in the
challenged Order. Accordingly, the Order must be vacated.
B.

This Court owes no deference to the FCC’s interpretation of
Section 276, which is unreasonable and attempts to infringe on
State authority.

The Commission will undoubtedly claim, as it did in its opposition to a stay,
that its interpretation of Section 276 is owed deference, asking this Court to accept its
view rather than having the Court exercise independent judicial authority to say what
the law is. But no such deference is owed to the Commission.

108

See Hearth, Patio & Barbecue Ass’n v. U.S. Dep’t of Energy, 706 F.3d 499, 505 (D.C.
Cir. 2013) (rejecting agency’s attempt to regulate new category of things when, until
the latest agency action, those things had never been regulated under the statute).

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Deference is not owed because any ambiguity in the statute
should be resolved against interpretations that infringe on
State authority to regulate intrastate rates.

Because courts presume that Congress does not intend to encroach on state
authority—a presumption which applies with special force to the Communications
Act—to the extent there is any ambiguity in the statutory text, that ambiguity is
resolved in favor of not allowing the Commission to infringe on the States’ authority
to regulate intrastate rates. Thus, a Chevron analysis is not applicable to a case like
this.109
The Commission’s Order seeks to preempt the State and local government
Petitioners’ authority in this case. The Order purports to set intrastate rates—an
authority reserved for and exercised by the States.110 It seeks to alter how States
manage and fund programs in their jails and prisons—a core area of traditional state
power111—and questions the legitimacy of state and local criminal justice practices.

109

Cf. Cobell v. Norton, 240 F.3d 1081, 1101 (D.C. Cir. 2001) (holding that “Chevron
deference is not applicable in” case involving Indian claims because “[t]he governing
canon of construction requires that ‘statutes are to be construed liberally in favor of
the Indians, with ambiguous provisions interpreted to their benefit.’ (citation
omitted)).

110

Louisiana Pub. Serv. Comm’n v. F.C.C., 476 U.S. 355, 360 (1986); see also, e.g., Order,
Pai dissent at 202, J.A.__ (providing examples of state regulation of ICS rates); Ind.
Code §§ 5-22-23-5, -6 (regulating ICS rates).
111

See, e.g., Florence v. Bd. of Chosen Freeholders, 132 S. Ct. 1510, 1515-16 (2012); O’Lone v.
Estate of Shabazz, 482 U.S. 342, 349 (1987).

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Throughout the Order, the Commission repeatedly makes clear that it “will preempt
state laws that are inconsistent with the federal framework” established in the
Order.112 States will no longer be able to receive the site commissions for which they
contracted (which are sometimes mandated by state statute)113 and to the extent that
States will seek to enforce those contractual provisions, the Commission asserts its
authority to preempt State law.114
But “because the States are independent sovereigns in our federal system,”115 it
“has long been settled [that courts] presume federal statutes do not … preempt state
law.”116 Thus, “it is incumbent upon the federal courts to be certain of Congress’s
intent before finding that federal law overrides the usual constitutional balance of
federal and state powers.”117 In other words, any rule that purports to “affect[] the
federal balance” requires a “clear statement” before presuming Congress intended

112

See Order ¶¶ 9, 204-05, 212-16, J.A.__, __, __.

113

2012 NPRM, ¶ 38, J.A.__.

114

Order, ¶¶ 215-16, J.A.__.

115

Medtronic, Inc. v. Lohr, 518 U.S. 470, 485 (1996).

116

Bond v. United States, 134 S. Ct. 2077, 2088 (2014) (citation omitted).

117

Id. at 2089 (citations and internal marks omitted) (emphasis added).

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such a result.118 In this way, “it is appropriate to refer to basic principles of federalism
embodied in the Constitution to resolve ambiguity in a federal statute.”119
Moreover, this presumption is reflected in the Communications Act itself,
which in Section 152(b) “expressly den[ies] th[e] agency ‘jurisdiction with respect to
intrastate communication service.’”120 Accordingly, “§ 276 should not be read to
confer upon the FCC jurisdiction” over intrastate rates “unless § 276 is ‘so
unambiguous or straightforward so as to override the command of § 152(b).’”121 This
is “not only a substantive jurisdictional limitation on the FCC’s power, but also a rule
of statutory construction.”122 It applies to any regulation of intrastate rates, regardless
of whether it preempts any particular State action or not. This is further fortified by
Section 601(c) of the Telecommunications Act of 1996 (the same Act that created
Section 276), which provides that the Act “shall not be construed to modify, impair,
or supersede” any State or local “law unless expressly so provided.” Thus, even

118

Id. (citations and internal marks omitted).

119

Id. at 2090; see also Am. Bar Ass’n v. F.T.C., 430 F.3d 457, 471-72 (D.C. Cir. 2005).

120

Louisiana Pub. Serv. Comm’n, 476 U.S. at 360 (quoting 47 U.S.C. § 152(b)).

121

Illinois Pub. Telecomms. Ass’n, 117 F.3d at 561 (citation and internal marks omitted).

122

Louisiana Pub. Serv. Comm’n., 476 U.S. at 373; see also New England Pub. Commc'ns
Council, 334 F.3d at 78 (“Such general provisions [in Section 276] cannot, however,
trump section 152(b)’s specific command that no Commission regulations shall
preempt state regulations unless Congress expressly so indicates.”) (citing Iowa Utils.
Bd., 525 U.S. at 381 n. 8 (“Insofar as Congress has remained silent … § 152(b)
continues to function.”)).

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though Section 276(c) contains an express preemption clause, Section 152(b), Section
601(c), and principles of federalism dictate that any authority to regulate intrastate
rates provided by Section 276 must be narrowly construed and any ambiguity as to the
Commission’s authority must be resolved against the interpretation that results in
greater infringement on State authority to regulate intrastate rates.123 The Commission
itself has recognized that its authority to regulate intrastate rates must be strictly
construed, and this Court agreed with that interpretive rule.124
With these principles in mind, this case is easily resolved. Section 276(b)(1)(A)
infringes on State authority to regulate intrastate rates in only a narrow field: Ensuring
that payphone providers are sufficiently compensated so as to compete with Bell
companies for the provision of payphone services. Any State laws that deprive
payphone providers of this compensation floor can be preempted, but no other State
action relating to payphone rates is affected. The Commission, in contrast, seeks to
interpret Section 276 to give it much broader authority over intrastate rates,
permitting the Commission to override State law as the arbiter of what is “just,

123

Medtronic, 518 U.S. at 485 (rejecting argument that “this assumption should apply
only to the question whether Congress intended any pre-emption at all, as opposed to
questions concerning the scope of its intended invalidation of state law,” and instead
using “the presumption against the pre-emption of state police power regulations to
support a narrow interpretation of [] an express [preemption] command”).
124

See New England Publ. Commc’ns Council, 334 F.3d at 73, 78.

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reasonable and fair” in every rate charged for every intrastate payphone call in every
context.

If this Court finds that Section 276 is ambiguous between these two

interpretations, both principles of federalism and Section 152(b)’s command that
“nothing in this chapter shall be construed to apply or to give the Commission
jurisdiction” over intrastate charges require the Court to adopt Petitioners’
interpretation. Ambiguity is resolved in favor of the States, the Order is invalidated,
State authority over intrastate rates is preserved, and Chevron’s deference is never
reached.
2.

Deference is not owed because the meaning of the statute
can be discerned after application of traditional tools of
statutory construction.

Deference to any agency interpretation is only a possibility if the statute’s
meaning cannot be discerned after applying traditional tools of statutory
construction.125 In the Commission’s view, because a portion of a single word in the
statute—“fair”—can have multiple meanings, the statute is ambiguous and the Court
must defer to whatever construction the Commission dreams up. But in a Chevron
analysis, “ambiguity is a creature not of definitional possibility but of statutory
context.”126 Therefore, “[t]he issue is not so much whether the word [‘fair’] is, in some

125

See Hearth, Patio & Barbecue Ass’n, 706 F.3d at 503; see also Chevron, U.S.A., Inc. v.
Nat. Res. Def. Council, Inc., 467 U.S. 837, 843 n.9 (1984).
126

Brown v. Gardner, 513 U.S. 115, 118 (1994)
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abstract sense, ambiguous, but rather whether, read in context and using the
traditional tools of statutory construction, the term” encompasses the Commission’s
attempted actions in this case.127
Applying the tools of statutory construction, as Petitioners have done above,
the meaning of the term “fairly compensated” in Section 276(b)(1)(A) is readily
discernable and unambiguously answers the question of whether the Commission has
the authority to set intrastate payphone rate caps to ensure their charges as “just,
reasonable, and fair” to the consumer: It does not. Chevron’s second step need not be
reached as the statute plainly does not authorize the agency actions taken in the
Order. “Government regulators simply cannot choose to ignore statutory limits on
their authority and expect deference to come of their intransigence.”128
3.

Deference is not owed because
interpretation is unreasonable.

the

Commission’s

Even if this Court reaches Chevron’s second step, deference is only warranted if
the Commission’s interpretation of Section 276 is “based on a permissible
construction of the statute” and is “reasonable in light of the Act’s text, legislative

127

California Indep. Sys. Operator Corp. v. F.E.R.C., 372 F.3d 395, 400 (D.C. Cir. 2004);
see also Don’t Tear It Down, Inc. v. Pennsylvania Ave. Dev. Corp., 642 F.2d 527, 533 (D.C.
Cir. 1980).

128

Hearth, Patio & Barbecue Ass’n, 706 F.3d at 506.

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history, and purpose.”129 But in light of all the indications of statutory meaning
detailed above, the Commission’s purported exercise in statutory interpretation is
unreasonable.
In the challenged Order, the Commission purported to set out its “Legal
Authority for Intrastate and Interstate Rate Caps,” but spends the bulk of the
discussion justifying their authority to impose some regulations relating to intrastate
ICS payphone compensation without addressing the scope of that authority.130
Throughout the Order, the Commission claims the authority to regulate intrastate
rates to ensure that they are “just, reasonable, and fair,”131 and purports to base that
authority on Section 276(b)(1)(A) simply by stating that the “fairly compensated”
mandate “must be read in conjunction with our obligation under section 201(b) to
ensure that charges and practices be just and reasonable.”132
This is entirely unreasonable. Well-accepted rules of statutory construction
counsel that the two provisions, when read together, show that Congress’s deliberate
choice of different words in Section 276 must lead to giving those words different

129

Glob. Crossing Telecommunications, 259 F.3d at 744.

130

Order, ¶¶ 106-113, J.A.__.

131

See supra note 76.

132

Order, ¶ 115, J.A.__.

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meaning from the “just and reasonable” language of Section 201(b).133 Instead, the
Commission does just the opposite by presuming that the different language in the
two provisions must mean the same thing.134 Moreover, the Commission makes
virtually no effort to discern the meaning of “fairly compensated” by applying any
other tools of statutory construction to the text, or to look to the statutory context,
structure, history, purpose, interpretation by contemporaneous agency rules or court
decisions, or legislative history. When those tools are applied, as they are above, the
inevitable conclusion is that Congress never gave the Commission the power to limit
the amount of compensation that ICS providers (or location providers like jails and
prisons) receive for their services.
The Commission’s Order unreasonably interprets Section 276 for two
additional reasons. Even if the statute’s notion of “fairly compensated” encompasses
some power to prevent overcompensation so that payphone providers do not make
too much profit, that is not what the Order does here. Section 276(b)(1)(A) is focused
on the payphone providers and compensation for costs incurred. But the focus of the
Order is not that ICS provider compensation is “unfair” because it greatly exceeds the

133

See authorities cited supra note 87.

134

See Order, O’Rielly dissent at 209, J.A.__ (noting that the Commission “mash[ed]
together bits and pieces of different provisions” and emphasizing that “[t]he
Commission is governed by a statute, not an optional menu. We don’t get to order a
la carte and make substitutions at will.”).

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provider’s cost. Rather, the Order seeks to prevent any compensation for a primary
driver of provider costs, namely commissions paid to jails and prisons.135 Those costs
are not illusory or being translated into unconscionable profits for the providers, but
instead being remitted to correctional facilities as a cost of doing business. The
Commission’s dispute is with local jails and state prisons, believing that the charges to
providers are illegitimate and having policy disagreements with the sovereigns’
criminal justice programs and their funding—an area far outside the Commission’s
expertise and authority. No reasonable interpretation of Section 276(b)(1)(A) gives the
Commission the power to dictate how jails and prisons fund their programs or to
prohibit the charges they levy on payphone providers for intrastate calls,136 or to
perversely use Section 276(b)(1)(A) to accomplish either of those tasks by deliberately
undercompensating ICS providers for costs that the providers actually incur on the
market.
The Order is also unreasonable because it fails to recognize the Section 276’s
distinction between the provision of payphone equipment (by ICS providers) and the

135

See Section II.B., infra.

136

See New England Pub. Commc’ns Council, 334 F.3d at 78 (Section 276(b)(1)(C)
authorizes the Commission to regulate certain Bell company charges to payphone
providers, but not to limit any other charges to providers).

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provision of operator and telecommunications line services (by carriers).137 The FCC
has previously conceded, and this Court has confirmed, that the agency cannot use its
Section 276 authority to regulate the rates non-Bell carriers charge payphone
providers for line services.138

The Commission cannot, nor ever has, regulated

intrastate toll rates charged by a carrier to an ICS provider for carrying toll traffic
under Section 276. The power to regulate carrier tolls, rather, is provided by Section
226 and is limited to interstate calls.139 By setting rate caps for intrastate calls, the Order
unreasonably applies Section 276 to regulate not just payphone equipment providers,
but also intrastate toll charges by carriers to those providers, which no reasonable
interpretation of Section 276 permits.
A final rule of construction is applicable here: deferring to the Commission in
this context should be avoided because it would take Chevron deference over the
constitutional edge.140 Under our constitutional system of separation of powers, “[i]t is
emphatically the province and duty of the judicial department to say what the law

137

Order, Pai Dissent at 200 n.26, J.A.__.

138

New England Pub. Commc’ns Council, 334 F.3d at 78.

139

See 47 U.S.C. § 226.

140

See I.N.S. v. St. Cyr, 533 U.S. 289, 299-300 (2001). Petitioners also preserve for
appeal the more general argument that Chevron deference itself it unconstitutional.

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is.”141 Deferring to the Commission’s “interpretation” of Section 276 here, which
lazily stares at the word “fairly” and without even attempting to engage in statutory
construction gives it any dictionary definition it fancies,142 would result in judicial
abdication to the Executive branch the “emphatic[]” duty to interpret law. That the
framers and the people who ratified the Constitution would have never countenanced
such Executive authority to “say what the law is” is well-established in history.143 The
Court should avoid this result by holding that the Commission’s Order setting rate
caps for intrastate ICS calls exceeds its statutory authority.
II.

The Order is unlawful because the Commission’s refusal to include the
costs of ICS to jails and prisons in its calculations is arbitrary and
capricious.
Among the costs facing any payphone service provider is the cost of locating

the phone equipment in a particular place. That is why Section 276 generally promotes
unfettered negotiation and contracting between location providers and payphone
providers.144 For the location provider, real estate isn’t free, and the fees charged to

141

Marbury v. Madison, 5 U.S. 137, 177 (1803).

142

Luna Torres v. Lynch, 136 S. Ct. 1619, No. 14-1096, Slip op. at 6 (May 19, 2016)
(because words “take[] on different meanings in different contexts, … staring at, or
even looking up, the words … cannot answer” the question of statutory
interpretation).
143

See PHILIP HAMBURGER, IS ADMINISTRATIVE LAW UNLAWFUL? 284-321 (2014).

144

See 47 U.S.C. § 276(b)(1)(E).

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payphone providers are a very real cost of doing business. Those costs increase greatly
when the location of the payphone is inside a jail or a prison, where security concerns
that result from giving inmates the privilege to use the telephone require extensive
effort to be mitigated.
In the challenged Order, the Commission decided that the costs to jails and
prisons for providing ICS—which are passed on to the ICS provider—are illegitimate
and, as a result, ICS providers are not entitled to any compensation (much less “fair”
compensation) for these costs. Thus, it calculated its rate caps without considering
these costs in an attempt to greatly reduce, if not eliminate, any compensation for the
costs of ICS borne by jails and prisons. This willful exclusion of relevant evidence is
arbitrary and capricious.
A.

Jails and prisons incur substantial costs directly related to the
provision of ICS.

Before it announces a rule, the Commission has a duty to “examine the
relevant data and articulate a satisfactory explanation for its action including a rational
connection between the facts found and the choice made.”145 The Commission
breaches that duty where it “relie[s] on factors which Congress has not intended it to
consider, entirely fail[s] to consider an important aspect of the problem, offer[s] an

145

Motor Vehicle Mfrs. Ass’n of U.S., Inc. v. State Farm Mut. Auto. Ins. Co., 463 U.S. 24, 43
(1983) (internal quotation marks and citation omitted).

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explanation for its decision that runs counter to the evidence before the agency, or is
so implausible that it could not be ascribed to a difference in view or the product of
agency expertise.”146 Agency action that results from such flawed reasoning is
“arbitrary and capricious.”147
From the start of this rulemaking initiative, the Commission has targeted
correctional facilities and their commissions as the culprit behind what the
Commission calls an “unjust” and “predatory” market.148 In its most recent attack on
these institutions, the Commission has decided to exclude those commissions from its
rate calculus, meaning that “any form of monetary payment, in-kind payment
requirement, gift, exchange of services or goods, fee, technology allowance, product
or the like,” payed from the service provider to the facility, was not considered a
“legitimate cost” for purposes of calculating the new rate caps.149 According to the
Commission, site commissions paid to correctional facilities “are not reasonably
related to the provision of ICS.”150

146

Id.

147

See id; see also 5 U.S.C. § 706.

148

See Order, ¶¶ 14, 118, J.A.__, __; id. at 194, J.A.__ (Statement of Commissioner
Clyburn) (“The truth is that each of us is paying a heavy price for what is now a
predatory, failed market regime.”).
149

Id. at ¶¶ 117-18, J.A.__ (emphasis added).

150

Id. at ¶ 123, J.A.__.

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But there was ample evidence before the Commission demonstrating that
facilities do, in fact, bear costs to provide ICS programs.151 Numerous jail and prison
officials provided comments in this proceeding and all of them share the same
sentiment: facilities spend much time and money providing ICS privileges.152 The
Commission’s decision to ignore these costs in its calculus is arbitrary and capricious.
For example, comments from facility operators in California, Illinois, Indiana,
and Massachusetts explain that their employees spend significant time facilitating and
monitoring the use of ICS.153 As the Sheriff of Imperial County, California, stated:
On a daily basis, staff monitors phone calls and many of those calls are
coordinating drug drop-offs between the inmates and their friends or
family members or people intentionally coordinating an arrest to bring in
and deliver illegal substances. … It is estimated that monitoring,
detecting, and following-up account for 25% of the workload for one
full-time Correctional Officer assigned to the Classification unit. This

151

See Order, Pai dissent at 204-06, J.A.__.

152

See generally Praeses LLC Comment 28-29 & n.67, J.A.__ (Jan. 12, 2015) (listing
facilities to have commented on the ICS rate initiative and detailing some of the costs
claimed by those facilities).
153

See Cook County Comment 3-5, J.A.__ (“The [Cook County 2013 cost study]
determined that labor hours equaling $2.4M were required to operate Cook County’s
ICS system[.]”); Marion County Sheriff Dec. 29, 2014 Ex Parte Letter at 2, J.A.__
(“Costs associated with Jail telephones are high due to the wanton destruction, and
unusual wear and tear. … At the Marion County Jail, we have staff dedicated to
making sure the telephones are in good repair. We have additional staff dedicated to
ensure inmates do not rig the telephone system and gain access to outside lines that
are not restricted. This is a constant and expensive endeavor.”); Barnstable County
Sheriff Comment 3, J.A.__ (“I have a Special Operations Unit that devotes a great
deal of time to listening to inmate phone calls.”).

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does not include any patrol response that may be required. …
Monitoring outbound calls is a necessary part of our job to enhance
facility and community safety, but it requires an extensive amount of
staff-time.154
A facility’s ICS role, however, does not stop with escorting prisoners to and
from the phones and monitoring what they say. It also includes enrolling and reenrolling detainees in biometric identification systems, retrieving and copying call
recordings in response to subpoenas, administering and managing payment and billing
systems, and updating and maintaining do-not-call lists to protect witness, judges,
prosecutors, and other potential victims.155 Thus, while ICS providers do provide the
hardware, software, and network infrastructure, the facilities themselves incur
significant costs in ICS provision.156
Multiple facilities included hard data in their filings, detailing things like laborhours and actual dollars spent in maintaining ICS programs.157 The most

154

Imperial County Sheriff Jan. 12, 2015 Letter at 2, J.A.__.

155

See National Sheriff’s Association Comments 2-3, J.A.__ (Jan. 12, 2015); Cook
County Comment 3, J.A.__; Imperial County Sheriff Jan. 12, 2015 Letter 2, J.A.__;
National Sheriff’s Association June 12, 2015 Ex Parte Letter 2, J.A.__; Letter from
Sheriff John Bishop (Ret.), Executive Director, Oregon State Sheriff’s Office
Association, to Tom Wheeler, et al., Chairman, FCC, at 2-3, J.A.__ (Jan. 5, 2015).
156

See National Sheriff’s Association June 12, 2015 Ex Parte Letter 2, J.A.__ (stating
that, while ICS providers often provide the technology, it is jail officers that
implement it).

157

See, e.g., Cook County Comment 3-5, J.A.__ (breaking down the $2.4 million Cook
County spent on ICS-related functions in 2013); id. at Exhibit 1, 2-4, J.A.__ (detailing
(Cont'd on next page)

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comprehensive source for that data came from a survey conducted by the National
Sheriff’s Association.158 That survey included data from correctional facilities in
twenty-three states, including the District of Columbia, and representatives from all
facility-size categories.159 The survey showed that, not only do facilities perform
integral parts of ICS provision, but also that performing those functions can cost
facilities anywhere from less than $0.01 per minute to upward of $0.40 per minute,
depending largely on the facility’s size and security requirements.160 For some facilities,
that translates into an average of over $100,000 per month in ICS-administration and
security costs.161 Indeed, without receiving any revenue from ICS, some jails and
prisons may greatly reduce ICS or eliminate it entirely.162

(Cont'd from previous page)

the number of hours correctional officers spent performing ICS related duties);
Imperial County Sheriff Jan. 12, 2015, Letter at 2, Table 1, J.A.__.
158

See generally, National Sheriff’s Association Comment Exhibit A, J.A.__; see also
National Sheriff’s Association June 12, 2015 Ex Parte Letter, J.A.__.

159

National Sheriff’s Association June 12, 2015, Ex Parte Letter 2, J.A.__.

160

National Sheriff’s Association Comment Exhibit A, J.A.__; National Sheriff’s
Association June 12, 2015 Ex Parte Letter 3, J.A.__.
161

National Sheriff’s Association Comment, Exhibit A, J.A.__ (calculating average
monthly costs for respondent 148).
162

See, e.g., Letter from JLG Technologies, LLC, to Marlene H. Dortch, Secretary,
FCC, Attachment C, p. 10, J.A.__ (Jul. 30, 2013) (“If the FCC chooses to decouple
the cost of the ICS from the cost of security for the ICS we believe it is highly
probable that the net result will be that correctional agencies will be forced to
(Cont'd on next page)

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Data provided by the ICS providers corroborated that provided by jails and
prisons. For example, Pay Tel explained that “jails, not ICS providers, perform the
lion’s share of administrative tasks associated with the provision of ICS and, more
importantly, jail officers handle ALL of the monitoring of inmate calls.”163 Pay Tel
also provided a chart, detailing the division of labor between correctional facilities and
ICS providers with respect to administrative and security-based ICS functions.164 That
chart demonstrated that, of the thirty functions listed, Pay Tel routinely assisted in
only two of them, whereas facility personnel were entirely or mostly responsible the
remaining twenty-eight.165

(Cont'd from previous page)

significantly reduce inmate access to phones.”); Letter from Combined Public
Communications, Inc., to Marlene H. Dortch, Secretary, FCC, at 2, J.A.__ (Dec. 22,
2014) (“If jails have absolutely no monetary incentive to put forth the time and
resources needed to ensure that their inmates have access to a well-functioning and
secure telephone platform, some facilities, particularly small ones, may simply decline
to allow or at least reduce the amount of telephone contact with family and friends.”);
NCIC Comments 3-4, J.A.__ (Jan. 12, 2015); Letter from County of Butler,
Pennsylvania, Prison Board, to Marlene H. Dortch, Secretary, FCC, at 1, J.A.__ (Dec.
29, 2014); National Sheriff’s Association Comment 7, J.A.__.
163

Letter from Pay Tel Communications, Inc. to Marlene H. Dortch, Secretary, FCC,
at 3, J.A.__ (May 8, 2015).
164
165

Id. at 9-12, J.A.__.
Id.

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Similarly, ICS providers CenturyLink166 and Securus Technologies167 also
submitted charts showing that correctional facilities perform administrative and
security-based ICS functions. One of the smaller ICS providers, Network
Communications International Corp. (NCIC), explained that, in smaller, more remote
locations, correctional facility staff may handle up to 90% on the onsite work.168
Indeed, even Global Tel*Link (the provider that has been most conservative in its
facility-borne cost analysis) admits that “facility-level ICS costs not borne by the
telecommunications provider are non-trivial and may vary significantly by contract.”169
B.

The Commission failed to provide a reasoned basis for excluding
all facility-borne costs in its calculation of rate caps.

Despite the evidence that jails and prisons incur real and substantial costs in
allowing access to ICS, the Commission decided to exclude all such costs in
calculating the rate caps. In so doing, the Commission failed to “cogently explain”

166

CenturyLink Letter to Marlene H. Dortch, Secretary, FCC, Attachment A, J.A.__
(Sept. 19, 2014).
167

Securus Technologies, Inc. Letter to Marlene H. Dortch, Secretary, FCC, J.A.__
(Dec. 8, 2014).

168

Network Communications International Corp. Letter to Marlene H. Dortch,
Secretary, FCC, at 1, J.A.__ (Dec. 17, 2014).
169

Global Tel*Link Corp. Letter to Marlene H. Dortch, Secretary, FCC, Attachment
2, p. 11, J.A.__ (Sept. 19, 2014).

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that willfully-blind decision and thus failed to demonstrate that its rate caps are “the
product of reasoned decisionmaking.”170
The Commission essentially puts forth two excuses: (1) the data quantifying
facility-borne costs has flaws and (2) the rate-caps are generous enough to absorb any
such costs without considering them in calculating the caps. None of these can be
supported in the record to justify complete exclusion of facility costs in calculating the
rate caps.
First, the Commission attempts to excuse ignoring the evidence of facilityborne costs by denouncing its reliability.171 But this does not explain the exclusion of
every claimed facility-borne cost. Conclusory complaints of “uncertainty” are not a
justification for agency action.172 As detailed above, there is significant data in the
record suggesting that facilities bear costs in the provision of ICS programs and
virtually no data to support the Commission’s conclusion that no facility incurs any
ICS-related costs. The best the Commission can point to is uncertainty over the

170

Owner-Operator Ind. Drivers Ass’n, Inc. v. Federal Motor Carrier Safety Admin., 494 F.3d
188, 203 (D.C. Cir. 2007) (quoting State Farm, 463 U.S. at 48, 52).

171

See generally, Order, ¶¶ 133-140, J.A.__.

172

See State Farm, 463 U.S. at 52-55.

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amount of those costs.173 But data will never be perfect or certain, especially where the
Commission vainly hopes for consistent data between facilities with vastly different
security needs and costs.174 Faced with less-than-ideal data, the Commission’s
obligation is to either (1) “determine as best it can” ICS-related facility costs175 or (2)
refuse to set any rate caps until it can obtain data sufficiently reliable for its
purposes.176 By acting as if jails and prisons bear no costs in allowing ICS simply
because the amount of those costs cannot be established with certainty is arbitrary
and capricious.
Second, the Commission claims that it need not consider the costs of ICS to jails
and prisons because, “if facilities incurred any legitimate costs in connection with ICS,
[the record indicates] those costs would likely amount to no more than one or two
cents per billable minute,” which the rate caps are “sufficiently generous to cover.”177
But in doing so, the Commission abandons its (already flawed) “averages” approach

173

See Order, ¶¶ 136-37, J.A.__; see also Order, Pai dissent at 205, J.A.__ (noting that
the record is clear that such costs exist and “[t]he only dispute is the amount of those
costs”).
174

See Order, Pai dissent at 203-04, 206 & n.61, J.A.__, __.

175

Bus. Roundtable v. S.E.C., 647 F.3d 1144, 1148, 1150 (D.C. Cir. 2011).

176

See Order, Pai dissent at 205, J.A.__ (“Notably, the FCC did not ask for these data
as part of its mandatory collection, so these estimates are the best record evidence
available.”).

177

Order, ¶ 139, J.A.__.

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and arbitrarily choses the lowest estimates of cost in the record, with other estimates
putting the number closer to 5, 6, or 9 cents a minute on average,178 and as high as 40
cents a minute for certain facilities.179
The Order also justifies this in part by pointing to the mere fact that certain
states have prohibited site commissions and still offer ICS.180 But the Commission did
not point to any data to suggest that provision of ICS in those states is costless to the
facility. Indeed, as Commissioner Pai points out in dissent, in one state cited to as an
example (New York) “the legislature made up for the shortfall through ‘budget
increases and the elimination of some inmate services.’”181 The same has been true in
other States.182
Moreover, even if such a cushion existed, the Commission then relies on it to
cover not just facility-borne costs, but a whole host of other, excluded costs. Those
include things like processing and billing costs,183 taxes and other third-party

178

See Order, Pai dissent at 205.

179

National Sheriff’s Association Comment Exhibit A, J.A.__; National Sheriff’s
Association June 12, 2015 Ex Parte Letter at 3, J.A.__.
180

Order, ¶ 138, J.A.__.

181

Order, Pai dissent at 205 n.76, J.A.__.

182

Id.

183

See FCC Order Denying Stay at ¶¶ 45-46, J.A.__.

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transactional costs,184 costs associated with new service and technology,185 and
inflation.186 The cushion, at some point, must disappear, but the Commission refused
to consider that possibility as it swept more and more costs under the rug. Double
counting is a capricious way to go about rulemaking.
And even if such a cushion existed, and even if it were “generous” enough to
cover all of those currently excluded costs, it would still only help those ICS providers
and facilities that were operating at average to below average operating costs.187 As
more fully explained in the ICS Providers’ Brief, considering the fact that the rate caps
are only calculated to cover the costs of an “efficient” operator,188 the likelihood that
the caps are high enough to allow reimbursement to facilities for their legitimate
costs—as well as the ancillary costs also excluded from the calculus—is
mathematically irrational.
The excuses and the evidence demonstrating facility-borne ICS costs
demonstrate that the Commission is engaged in a method of decisionmaking that
started with a conclusion (to lower call rates for inmates) and then sought out reasons

184

See id. at ¶¶ 45, 48-49, J.A.__.

185

See id. at ¶¶ 45, 51, J.A.__.

186

See Order , ¶ 71, n.221, J.A.__.

187

See Order, Pai dissent at 205-06, J.A.__.

188

See Order, ¶ 71, J.A.__ (“An analysis of the adopted rate caps shows that some
providers will recover more than their stated costs, while other will recover less[.]”).

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and theories to support it—excluding those to the contrary along the way. That kind
of confirmation bias cannot be described as “reasoned.” Rather, it is arbitrary,
capricious, and unlawful.
C.

Because Section 276 requires the Commission to ensure fair
compensation to payphone service providers for all costs,
exclusion of the cost of site commissions is arbitrary and
capricious.

As noted above in Section I.B.3, the Commission’s order exceeds its statutory
authority because it uses Section 276 to deliberately undercompensate ICS providers.
But this same reality can also be seen as an additional reason why the Order is
arbitrary and capricious. An agency action is arbitrary and capricious if the agency
“relied on factors which Congress has not intended it to consider.”189 As detailed
above, the text, context, history, and purpose of Section 276(b)(1)(A) all demonstrate
that Congress was concerned with providers being “fairly compensated” for costs
actually incurred in providing payphone service. Nothing indicates that Congress
intended that the Commission examine the practices of location providers (like jails
and prisons) and question the legitimacy of the costs imposed on payphone providers
by location providers based on how location providers choose to use their revenue.
Section 276(b)(1)(A) commands the Commission to ensure that payphone providers
are compensated for all costs incurred in providing payphone service rather than to
189

State Farm, 463 U.S. at 43.

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rely on as a factor what facilities do with revenue gained from imposing those costs.
Indeed, such attempts to restructure the market by requiring that payphone providers
be undercompensated flips Section 276 on its head.
CONCLUSION
For the foregoing reasons, this Court should vacate the challenged Order. If
the Court determines that the Commission is without authority to set intrastate caps,
vacatur is the appropriate relief since no possible revised order could remedy this
problem. Similarly, if the Court finds the Order arbitrary and capricious, it should
vacate the Order because failure to account for site costs and respond to empirical
data in its rate determination is a serious deficiency, as those costs are a primary driver
of ICS rates, and because vacatur will maintain the status quo since enforcement of
the Order has been stayed by this Court.190

190

See Comcast Corp. v. F.C.C., 579 F.3d 1, 8-9 (D.C. Cir. 2009).

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DATED: June 6, 2016

Respectfully submitted,

James Bradford Ramsay
General Counsel
Jennifer Murphy
Assistant General Counsel
National Association of Regulatory
Utility Commissioners
1101 Vermont Avenue, N.W., Suite 200
Washington, D.C. 20005
P: (202) 898-2207
E: jramsay@naruc.org

/s/ Mithun Mansinghani___________
E. Scott Pruitt
Attorney General of Oklahoma
Patrick R. Wyrick
Solicitor General
Mithun Mansinghani
Deputy Solicitor General
Oklahoma Office of the Attorney General
313 NE 21st Street
Oklahoma City, OK 73105
P: (405) 521-3921
E: Mithun.Mansinghani@oag.ok.gov

COUNSEL FOR NATIONAL ASSOCIATION
OF REGULATORY UTILITY COMMISSIONERS COUNSEL FOR THE STATE OF OKLAHOMA
Danny Honeycutt
Oklahoma County Sheriff’s Office
201 N. Shartel Ave.
Oklahoma City, OK 73102
P: (405) 713-2050
E: sodanhon@okcounty.org

Christopher J. Collins
Collins, Zorn & Wagner
429 NE 50th Street, 2nd Floor
Oklahoma City, OK 73105
P: (405) 524-2070
E: cjc@czwglaw.com

COUNSEL FOR JOHN WHETSEL, SHERIFF
OF OKLAHOMA COUNTY, OKLAHOMA

COUNSEL FOR OKLAHOMA SHERIFFS’
ASSOCIATION

Mark Brnovich
Attorney General of Arizona
Dominic E. Draye
Deputy Solicitor General
Arizona Office of the Attorney General
1275 West Washington
Phoenix, AZ 85007
P: (602) 542-5025
E: dominic.draye@azag.gov

Leslie Rutledge
Attorney General of Arkansas
Lee Rudofsky
Solicitor General
Arkansas Attorney General
323 Center Street, Suite 200
Little Rock, AR 72201
P: (501) 682-8090
E: lee.rudofsky@arkansasag.gov

COUNSEL FOR STATE OF ARIZONA

COUNSEL FOR STATE OF ARKANSAS
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Karla L. Palmer
Hyman, Phelps & McNamara, P.C.
700 13th Street, N.W., Suite 1200
Washington, D.C. 20005
P: (202) 737-5600
E: kpalmer@hpm.com

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Gregory F. Zoeller
Attorney General of Indiana
Thomas M. Fisher
Solicitor General
Office of the Indiana Attorney General
302 W. Washington Street
IGC-South, Fifth Floor
Indianapolis, IN 46204
P: (317) 232-6255
E: Tom.Fisher@atg.in.gov

Tonya J. Bond
Joanne T. Rouse
Plews Shadley Racher & Braun LLP
1346 N. Delaware Street
Indianapolis, IN 46202
P: (317) 637-0781
E: tbond@psrb.com
E: jrouse@psrb.com

COUNSEL FOR STATE OF INDIANA
Jeff Landry
Attorney General of Louisiana
Patricia H. Wilton
Assistant Attorney General
Louisiana Department of Justice
1885 North Third Street
Baton Rouge, LA 70802
P: (225) 326-6006
E: wiltonp@ag.louisiana.gov

COUNSEL FOR THE INDIANA SHERIFFS’
ASSOCIATION, MARION COUNTY
SHERIFF’S OFFICE, AND LAKE COUNTY
SHERIFF’S DEPARTMENT
Derek Schmidt
Attorney General of Kansas
Jeffrey A. Chanay
Chief Deputy Attorney General
Kansas Office of the Attorney General
Memorial Hall, 3rd Floor
120 SW 10th Avenue
Topeka, KS 66612-1597
P: (785) 368-8435
E: jeff.chanay@ag.ks.gov

COUNSEL FOR STATE OF LOUISIANA
Chris Koster
Attorney General of Missouri
J. Andrew Hirth
Deputy General Counsel
Missouri Office of the Attorney General
P.O. Box 899
207 W. High Street
Jefferson City, MO 65102
P: (573) 751-0818
E: andy.hirth@ago.mo.gov

COUNSEL FOR STATE OF KANSAS

COUNSEL FOR STATE OF MISSOURI

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Adam Paul Laxalt
Attorney General of Nevada
Lawrence VanDyke
Solicitor General
Office of the Nevada Attorney General
100 N. Carson Street
Carson City, NV 89701-4717
P: (775) 684-1100
E: LVanDyke@ag.nv.gov

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Brad D. Schimel
Attorney General of Wisconsin
Misha Tseytlin
Solicitor General
Daniel P. Lennington
Deputy Solicitor General
Wisconsin Department of Justice
Post Office Box 7857
Madison, WI 53707-7857
P: (608) 267-9323
E: tseytlinm@doj.state.wi.us

COUNSEL FOR STATE OF NEVADA

COUNSEL FOR STATE OF WISCONSIN

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CERTIFICATE OF COMPLIANCE
The undersigned counsel certifies that this brief complies with the typeface
requirements of Fed. R. App. P. 32 because this brief has been prepared in a
proportionally spaced typeface using Microsoft Word 2010 in Garamond, 14-point.
This brief complies with the type-volume limitation of Fed. R. App. P. 32(a)(7)(B) and
this Court’s briefing order because it contains 13,856 words, excluding the parts
exempted from brief requirements under Fed. R. App. P. 32(a)(7)(B)(iii).
/s/ Mithun Mansinghani
Mithun Mansinghani

CIRCUIT RULE 32(A)(2) ATTESTATION
Pursuant to D.C. Circuit Rule 32(a)(2), I hereby attest that all other parties on
whose behalf this joint brief is submitted concur in the brief’s content.
/s/ Mithun Mansinghani
Mithun Mansinghani

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CERTIFICATE OF SERVICE
I hereby certify that, on June 6, 2016, a true and correct copy of the foregoing
Brief of State and Local Government Petitioners was served via the Court’s CM/ECF
system on counsel of record for all parties.
/s/ Mithun Mansinghani
Mithun Mansinghani

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ADDENDUM
STATUTES AND REGULATIONS ..........................................................................................A1
AFFIDAVIT OF JONATHAN SKUTA,
OKLAHOMA COUNTY SHERIFF’S OFFICE ............................................................A5
AFFIDAVIT OF TINA HICKS,
OKLAHOMA DEPARTMENT OF CORRECTIONS................................................ A12
AFFIDAVIT OF MICHAEL P. KEARNS,
ARIZONA DEPARTMENT OF CORRECTIONS .....................................................A18
AFFIDAVIT OF STEPHEN P. LUCE,
INDIANA SHERIFFS’ ASSOCIATION ......................................................................A21

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STATUTES AND REGULATIONS
47 U.S.C. § 152
(a) The provisions of this chapter shall apply to all interstate and foreign
communication by wire or radio and all interstate and foreign transmission of energy
by radio, which originates and/or is received within the United States, and to all
persons engaged within the United States in such communication or such
transmission of energy by radio, and to the licensing and regulating of all radio
stations as hereinafter provided; but it shall not apply to persons engaged in wire or
radio communication or transmission in the Canal Zone, or to wire or radio
communication or transmission wholly within the Canal Zone. The provisions of this
chapter shall apply with respect to cable service, to all persons engaged within the
United States in providing such service, and to the facilities of cable operators which
relate to such service, as provided in subchapter V-A.
(b) Exceptions to Federal Communications Commission jurisdiction
Except as provided in sections 223 through 227 of this title, inclusive, and section 332
of this title, and subject to the provisions of section 301 of this title and subchapter VA of this chapter, nothing in this chapter shall be construed to apply or to give the
Commission jurisdiction with respect to (1) charges, classifications, practices, services,
facilities, or regulations for or in connection with intrastate communication service by
wire or radio of any carrier, or (2) any carrier engaged in interstate or foreign
communication solely through physical connection with the facilities of another
carrier not directly or indirectly controlling or controlled by, or under direct or
indirect common control with such carrier, or (3) any carrier engaged in interstate or
foreign communication solely through connection by radio, or by wire and radio, with
facilities, located in an adjoining State or in Canada or Mexico (where they adjoin the
State in which the carrier is doing business), of another carrier not directly or
indirectly controlling or controlled by, or under direct or indirect common control
with such carrier, or (4) any carrier to which clause (2) or clause (3) of this subsection
would be applicable except for furnishing interstate mobile radio communication
service or radio communication service to mobile stations on land vehicles in Canada
or Mexico; except that sections 201 to 205 of this title shall, except as otherwise
provided therein, apply to carriers described in clauses (2), (3), and (4) of this
subsection.

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47 U.S.C. § 201
(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
(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;
(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
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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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IN THE UNITED STATES COURT OF APPEALS
FOR THE DISTRICT OF COLUMBIA CIRCUIT
STATE OF OKLAHOMA, et al.

)
)
Petitioners,
)
)
v.
)
)
)
FEDERAL COMMUNICATIONS )
COMMISSION, et al.,
)
)
Respondents.
)
______________________________ )

Case No. 16-1057
(Consolidated with No. 15-1461)

AFFIDAVIT OF STEPHEN P. LUCE
Stephen P. Luce, hereby swears under penalty of perjury to the truth of the
following statements:
1.

I am the Executive Director of the Indiana Sheriffs’ Association

(“ISA”). I have been in this position since February 1, 2009.
2.

From January 1, 2003 to January 31, 2009, I also was the elected

Sheriff for Knox County, Indiana.
3.

From my knowledge and experience in these two positions as well as

input from current elected Sheriffs in the State of Indiana, all of whom are
members of the ISA, it is clear that the County Jails in the State of Indiana will be
financially impacted by the Federal Communications Commission’s final agency
action, In re Rates for Interstate Inmate Calling Services, Second Report and
1

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Order and Third Further Notice of Proposed Rulemaking, Rates for Interstate
Inmate Calling Services, WC Docket No. 12-375, FCC 12-167 (Nov. 5, 2015) (the
“Order”).
4.

Indiana has 92 County Sheriffs, and the County Jails are classified as

large, medium, or small. On average, the Indiana County Jails are at about 83%
capacity. Due to recent Indiana legislation that will keep low-level offenders in
County Jails who would otherwise go to the Department of Corrections after
sentencing, I anticipate an increase in County Jail inmate population in the near
future. This will lead to an increase in inmate calling services (“ICS”) at the
County Jails.
5.

County Jails in Indiana Counties with populations greater than 75,000

are subject to and comply with the same telecommunications standards as the
Indiana Department of Corrections pursuant to state statute Indiana Code § 5-2223-6. The Marion County Sheriff’s Office and the Lake County Sheriff’s
Department, both named Intervenors, are large County Jails.
6.

Each of Indiana’s Sheriffs with the exception of one runs a County

Jail. Those that run a County Jail provide ICS through their individual contracts
with an ICS provider (the “ICS Contract”).

2

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The ICS Contract sets the rates that inmates pay for telephone and

other services. The ICS Contract provides the Sheriff’s Office with a site
commission based on the rate charged (“Site Commission”).
8.

The Indiana Sheriffs use a portion of the Site Commission to defray

costs directly related to ICS. This includes at least the following:
a. Administrative costs;
b. Monitoring and recording phone calls;
c. Monitoring inmates placing calls;
d. Maintain and administer lists of blocked numbers for judges,
witnesses, victims, jurors, etc.;
e. Preventing and remedying destruction of phones;
f. Preventing inmates from tampering with phones or using them to
access outside lines;
g. Enrollment and management of inmates into voice biometrics
systems;
h. Producing call recordings for investigatory requests and subpoenas;
i. Answering questions from inmates and families related to ICS;
j. Preparing, updated, and implementing ICS standard operating
procedures; and
k. Providing security for on-site ICS technicians.
3

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