How have the courts treated recordings of phone conversations between an inmate and his girlfriend in jailhouse phone lines?

California, United States of America

The following excerpt is from People v. Z.A. (In re Z.A.), F076624 (Cal. App. 2018):

jailhouse calls to his girlfriend "were not the product of 'custodial interrogation' " even though she secretly recorded them in cooperation with the police because "[f]rom defendant's perspective, he was talking with a friend and lover," and thus, his "statements were completely voluntary and compulsion-free"]; People v. Gonzales and Soliz (2011) 52 Cal.4th 254, 284 [although defendant "misplaced his trust" in confiding in a fellow inmate and gang member who surreptitiously recorded their conversation, "his tape-recorded statements were voluntary and free of compulsion"].)

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How have the courts treated recordings of phone conversations between an inmate and his girlfriend in jailhouse phone lines?

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