The use of fines as a criminal sanction has been a part of Anglo-American law for over six hundred years. From the inception of this penalty, however, law making bodies have had to deal with the convicted criminal who fails or refuses to pay the fine imposed upon him. The early non-paying offender faced being sold into slavery unless the necessary funds could be produced by family or friends. From such early remedies for default our present more civilized alternative of imprisonment arose.
Imprisonment of Indigent Defendants for Nonpayment of Fines,
U. Rich. L. Rev.
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