sshd[231]: error: open /dev/tty failed - could not set controlling tty: Permission denied

[Robert Westendorp]

sshd[231]: error: open /dev/tty failed - could not set controlling tty:
Permission denied

Anyone seen this error before? It's happening in a Jail after an upgrade
from 4.6-->4.9. The host machine is fine, and I can still ssh into the jail,
but it puts this error into /var/log/messages.

Any idea what's causing this?
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Robert