Can a criminal defendant obtain access to attorney-client correspondence from a private prison?

Criminal defendants have a Sixth Amendment right to assistance of counsel, and the right applies in state court proceedings. Gideon v. Wainwright , 372 U.S. 335, 33941, 83 S.Ct. 792, 9 L.Ed.2d 799 (1963). The right to counsel is violated when (1) "the government deliberately interferes with the confidential relationship between a criminal defendant and defense counsel," and (2) the interference "substantially prejudices the criminal defendant." Nordstrom I , 762 F.3d at 910. We have recognized a defendant's "ability to communicate candidly and confidentially" with defense counsel as "essential to his defense" and "nearly sacrosanct." Id. Thus, prison officials may not read an inmate's "outgoing attorney-client correspondence." Id. at 91011. However, prison officials may "inspect [ ] an inmate's outgoing mail, in his presence, to make sure that it does not contain, for example, a map of the prison yard, the time of guards' shift changes, escape plans, or contraband." Id. at 910.