It wouldn't be easy. No inmate in any federal, state, or local facility is allowed to receive phone calls. A sign posted by every inmate telephone in a federal detention center says something like, "This notice is to advise the user that all conversations from this telephone are subject to monitoring, and the use of the telephone constitutes consent to the monitoring." Having government officials listen in on your phone calls while committing a crime has a way of extending your federally funded vacation plans.