
U.S. court cases considering prisoners’ communication include Gerber v. Hickman, 291 F.3d 617 (2002), Overton v. Bazzetta, 539 U.S. 126, 123 S.Ct. 2162 (2003), and Beard v. Banks, 126 S.Ct. 2572 (2006). A considerable policy literature has developed around the issue of prisoner re-entry in free society. The U.S. Second Chance Act (Public Law 110-199) has established a National Reentry Resource Center. However, neither court cases nor the prisoner re-entry literature focuses on the broad public value of prisoners’ communication with persons not in prison.