The acceptance of restitution as a sentencing option is growing, because it helps compensate for victims' losses, encourages offender responsibility, uses less tax dollars than imprisonment, reduces prison overcrowding, and encourages crime reporting. Restitution also maintains society's condemnation of the criminal acts involved. Due in part to the Victim and Witness Protection Act of 1982, 2 States now have statutes that require consideration of restitution as a sanction in criminal cases. A central legal issue in the enforcement of restitution orders is the appropriate sanction for failure to comply with such orders. Courts have held that Bearden v. Georgia governs enforcement. In this case, the U.S. Supreme Court ruled that imprisonment cannot be based on a person's lack of financial resources. A failure to comply with restitution orders because of a financial circumstance beyond the offender's control cannot, therefore, be a cause for imprisonment. An alternative nonincarcerative sentence should be used. 216 footnotes.