year law student to argue this matter the plaintiff has approved it to dean has certified her in good standing in this court has issued an order allowing her to argue and i'd like to present her to this court man this case is really about is a man who was unable to talk to his family for eight years and is what's contention that in one nine hundred ninety four in washington versus reno this court clearly established prison officials cannot impose an a reasonable restrictions on telephone use when the prisoner has no other reasonable means to communicate with his family why is this unreasonable here it's reasonable and this case your honor because he had no other way to communicate with his family washington does not address the situation where individual had no other means of communicating with family does it know it doesn't here and instead also it's also fair to say that it stresses that certain limitations are restrictions on that right may be imposed right right and the reasons for the restrictions are not limited by washington correct i mean other words it doesn't have to necessarily be a security justification or penal logical justification it's not as to the purpose of the restrictions what what's a legitimate purpose right write it is silent as to that but it does state that the restrictions must be reasonable and we would argue that in this case the the restrictions are i'm a reasonable because they had already precluded him from writing letters to his family and receiving letters so there was no other way for him to communicate other than telephone use i think i'd like to see you on what about washington would have let these correctional officers know that it was constitutionally required for them to overlook the restrictions of the prison policy and instead to do something different to your client than what what was clearly established that would have made a reasonable officer know that what happened in this case was unconstitutional  argue that you can't ignore the constitution and simply blindly follow present policy it's known that it is bad prisoners have constitutional rights to communicate with their family the fact that he had no way for eight years while he was in prison to communicate with his family which show that there is a concert there is a constitutional right to communicate and if he's not being allowed to exercise his constitutional rights then it is it should be clearly institutions retain their first amendment rights to communicate with my family and friends and i also know that there is no legitimate government so part is to be attained by not allowing reasonable access to the telephone and such use protected by the first amendment but it also goes on as late as far as the telephone there can be subject to rational limitations right correct there with the washington also the way you interpret it put a rational limitation on the right to communicate just generally with your family can you rephrase the question in the first part of the sentence you read the there's a constitutional right on the first amendment for inmates to communicate with their families subject to read rational limitation yes they used to i'm sorry the use of the telephone is not an unlimited use it can be limited and the face of legitimacy get answered or maybe you didn't answer my question first  about so don't you lose that we know you're a reasonable official wouldn't have known based on just walking them that the limitations of the michigan prison policy would violate your client's constitutional i also sense the litigation in the lower court and the injunction and the defendants have submitted a notice of compliance and which they have expanded the countries that  phone access to to one hundred thirty countries so if there was any security interest it was very minimal after the that action that prison officials and you know a value w should the policy in this decision to comply with injunctive relief that's really a separate question from what these individual corrections officials were graced with in light of washington the rayna in the fact that a policy isn't that unconstitutional doesn't mean doesn't really tell us much in this kind of context about what a reasonable of the family of the state is not contesting that i mean they agree all right the it was unconstitutional limited and all that but what were their fussing about the only issue as i understand on appeal was w reasonable officer in two thousand and five or was it always as a result of this litigation in the injunction that you won and all that but that's not on appeal is the injunction or the fifty thousand dollars legal all that stuff we're just fussing about whether qualified immunity should apply to these individual four officers and the only issue on appeal yes you know i mean why is it so important for you to win this case for the plaintiff here does it really making a difference in how he's going to be treated by there was qualified immunity here or personal immunity or a personal liability it's important to show that it is clearly established that prisoners do have a right to communicate with their families but that's that's already been taken care of by the injunction has it not and the jury finding has has made that clear to it's not been a offered to set not true that's in front of me right now but other there was a disagreement as to what happened but i didn't think there was a disagree and the circumstances i don't think there was a disagreement that there was a discussion about their willingness to pay ten dollars it's my understanding that they did not offer to pay the ten dollars did they send a letter suggesting that they were going to pay for or some kind of communication or they tell the truth about that i don't believe  say there was no offer to settle the just the statement whether you would still take ten dollars and if he's willing let the council know and i mean that's an overt you're in really good sounds pretty promising offering to pay ten dollars this is not the truth plaintiff's counsel had informed if in its counsel that if offered ten dollars plaintiff was likely to agree to dismiss the appeal even prior to the briefing schedule being issued by this  your position is he's going to be he's he's going to feel much more been to get it because the money correct your honor and just to establish that the present officials can't blindly follow a policy and ignore the on reasonable restrictions on telephone access where the president has no other reasonable means to communicate with his family the jury found the prison official must then put must impose on reasonable restrictions i see that my time  up thank you the grant of qualified immunity should be reversed and this matter remanded to the district court for reinstatement of the jury's awarded damages thank you piers thank you for your argument missy we appreciate your interest in appellate advocacy and your being here today and i think you can take pride in having done well in your was presumably your first appearance  we will consider the case carefully