In court papers filed Wednesday, attorney Joseph Amendola opposed a request by state prosecutors to keep Sandusky inside his State College, Pa., home, where he has been under house arrest awaiting trial on child sexual abuse charges.
Amendola said Sandusky had obeyed the conditions of his bail and always obtained approval of a Centre County probation official to leave his house.
"Jerry can't open his front door to let his dog, Bo, out without someone contacting law enforcement authorities to report his whereabouts. For all practical purposes, he has been a prisoner in his own home since Nov. 5 when he was initially arrested," Amendola said in a statement.
The state attorney general's office on Tuesday asked Judge John M. Cleland to tighten the conditions of Sandusky's $250,000 bail to keep him indoors except in case of a medical emergency.
Senior Deputy Atty. Gen. Jonelle Eshbach cited complaints from neighbors who said they had seen Sandusky shoveling snow and standing on the rear deck of the house.
According to a memo from a state agent to probation officials, teachers at a nearby elementary school were concerned that Sandusky was watching the children play during recess. Such alarm "is totally unfounded," Amendola wrote in a court filing.
Sandusky, 68, faces 52 charges of sexually molesting 10 children. According to grand jury reports, the abuse occurred in his home, on the Penn State campus and elsewhere between 1994 and 2008.