State v. Wolfe

In State v. Wolfe (December 11, 2000), Madison App. No. CA-99-11-029, 2000 Ohio App, the defendant was prosecuted for having assisted her boyfriend in escaping from the Madison Correctional Institution. The recorded telephone conversations at issue detailed her complicity in the escape. An institution charged with the confinement of individuals would have at least as much of an interest in monitoring an external threat to the security of the institution as in monitoring an internal threat, especially where the essence of the conversation being monitored is the coordination of the external and internal threats. Parenthetically, in State v. Wolfe, supra, although inmates were advised that their outgoing telephone calls were subject to monitoring or recording, there was no similar advice to the external participants in those conversations.