few FTA statutes existed at the state level. New York and Minnesota were among the earliest adopters of statutes penalizing FTAs, but these laws were rarely used in practice. By 1966, only seven states had separate sanctions for FTAs. Over thirty states implemented FTA-specific penalties over the next two decades. These laws coincided with a growing national concern about dangerous defendants and the perceived need for greater deterrence in the pretrial system. The Bail Reform Act of 1966, one of the first significant pieces of the federal bail legislation, made "willfully fail[ing] to appear before any court or judicial officer as required" punishable by up to five years in prison and a $5,000 fine. In 1984, Congress increased the sanctions for FTAs in federal court. In early versions of the bill, lawmakers expressed their resolve to "deter those who would obstruct law enforcement by failing to appear for trial or other judicial appearances and to punish those who indeed fail to appear." Lawmakers saw heightening the penalties for FTAs "as a means of enhancing the effectiveness of the bail jumping offense as a deterrent to flight." Modern federal law Today, a defendant who "fails to appear before a [federal] court as required by the conditions of release" or "fails to surrender for service of sentence pursuant to a court order" remains subject to criminal sanctions. A court will use the following scheme to determine a defendant's punishment: A defendant can present an affirmative defense that "uncontrollable circumstances prevented" their appearance. To make this claim successfully, the defendant must not have contributed to the uncontrollable circumstances and must have "appeared or surrendered as soon as such circumstances ceased to exist." An "uncontrollable circumstance" can either be physical or mental, the latter of which courts refer to as "duress." Not all mental pressures satisfy the uncontrollable circumstance requirement; courts have held that only something as serious as threats of significant bodily harm or death can excuse an FTA. The prospect of prosecutorial reprisal, fear of harassment, and loss of faith in the criminal justice system generally do not amount to uncontrollable duress. Courts have dismissed claims based on fears of deportation and a defendant's desire "to make a political statement or engage in protest activity." The legislative history for the federal statute indicates that the affirmative defense should only apply in extreme circumstances: "for example, a person is recuperating from a heart