In a recent landmark decision, the Fourth Circuit held that the failure to provide a videophone to a prisoner who is deaf so that he can communicate with people outside of prison may violate his First Amendment rights. In a case brought by the Washington Lawyers’ Committee and Arnold & Porter Kaye Scholer LLP, Thomas Heyer challenged the Bureau of Prisons (BOP) for its failure to accommodate his deafness, including its failure to provide ASL interpreters for medical and mental health treatment, interpreters for religious services, warning lights in his cell and access to a videophone. The Court held that the “First Amendment rights retained by convicted prisoners include the right to communicate with others beyond the prison walls.”