Although monetary sanctions have been used as criminal punishments since the dawn of the American state,'the size and scope of these financial sanctions have increased dramatically in recent years. While there are no comprehensive data on the total amount of monetary sanctions that courts across the country have assessed defendants, the US General Accounting Office estimates that outstanding criminal debt rose from $260 million to over $13 billion between 1985 and 2001.2 Using a different method of accounting, the US Department of Justice estimated that outstanding criminal debt continued to rise from roughly $20 billion3 to roughly $100 billion4 between 2001 and 2014.

These monetary sanctions, which are also known as legal financial obligations (LFOs), include victim restitution, criminal fines, and court fees. Restitution is a payment made by an offender to compensate a victim for damages caused by the crime. 5 Although restitution was assessed in only about one-fifth of felony state court convictions in 2004, 6 increases in