as a sentence and then automatically convert it into "a jail term solely because the defendant is indigent and cannot forthwith pay the fine in full." And in the 1983 ruling for Bearden v. Georgia, the Court ruled that the Fourteenth Amendment bars courts from revoking probation for a failure to pay a fine without first inquiring into a person's ability to pay and considering whether there are adequate alternatives to imprisonment. A year-long study released in 2010 of fifteen states with the highest prison populations by the Brennan Center for Justice, found that all fifteen states sampled have jurisdictions that arrest people for failing to pay debt or appear at debt-related hearings. The study identified four causes that lead to debtors' prison type arrests for debts: State laws that attempt to make criminal justice debt a condition of probation, parole, or other correctional supervision with failure to pay resulting in arrest and reimprisonment. State laws that consider imprisonment as a penalty for failure to pay criminal justice debt. These actions are considered a civil contempt of court charge, thus technically not in violation of state constitutions that prohibit debtors' prisons, but for the same reason those incarcerated must be released immediately if they either pay or prove themselves unable to do so. Citizens choosing jail time under state programs where imprisonment is a way of paying down court imposed debt. States that regularly arrest citizens for criminal justice debt prior to appearing at debt-related hearings, leading in many cases to multi-day jail terms pending an ability to pay hearing. The routine jailing of people who owe civil debt when such debts are related to child support arrears. Imprisonment for such debt is legally justified by the legal fiction that the incarceration is not for the debt, but rather for not obeying a court order to pay the debt. In an article in The American Conservative, Michael Shindler argues that another factor responsible for debtors' prison type arrests is that "Whereas indigent defendants have a Sixth Amendment right to a court-appointed lawyer in criminal cases involving incarceration, indigent debtors in state and local courts have no one to defend them against the error and abuse that characterizes debt collection litigation." Similarly, Shindler writes, regarding explicitly illegal debtors' prison type arrests ordered by local judges,"the reason these officials engage in this sort of excessive behavior is often due to ignorance." In