Paul Lyons, 41, was caught with an iPhone in his cell at high security HMP Shotts.
Depute fiscal Tiffany Chisholm told the court: "A search was carried out of the accused's cell and he was compliant during the search."He was then asked if there were any items in the cell which he should not have to which he replied 'no'. Rosemary Robinson, defending, said: "He is serving a lengthy sentence which restricts the options available to the court."
Lyons was jailed at the High Court in 2010 for killing Mark Fleeman, 32, in a 100 miles per hour road rage attack.
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