for debt between 1808 and 1809 where he made use of his time by writing "Memoirs of the War". Debtors' prisons were prevalent throughout the United States up until the mid-1800s. Economic hardships following the War of 1812 with Great Britain helped swell prison populations with simple debtors. This resulted in significant attention being given to plights of the poor and most dependent jailed under the widespread practice, possibly for the first time. Increasing disfavor over debtors' prisons along with the advent and early development of U.S. bankruptcy laws led states to begin restricting imprisonment for most civil debts. At that time growing use of the poorhouse and poor farm were also seen as institutional alternatives for debtors' prisons. The United States ostensibly eliminated the imprisonment of debtors under federal law in 1833 leaving the practice of debtors' prisons to states. Changes to state debtors' prisons Kentucky 1821 – save where fraud was shown or suspected Ohio 1828 Maryland 1830 – for debts under $30 New Jersey 1830 Vermont 1830 Massachusetts 1831 – exempted women for any amount and men with debts under $10 New York 1832, Connecticut 1837, Louisiana 1840, Missouri 1845, Alabama 1848, Virginia 1849 Historic preservation Accomac, Virginia – constructed 1782–1783, converted to a "gaol [jail] for debtors" in 1824, closed 1849 Tappahannock, Virginia – constructed prior to 1769, converted to other uses 1849 Worsham, Virginia – authorized 1786, constructed as a "gaol [jail] for debtors" 1787, closed sometime between 1820 and 1849 Modern debtors' prisons (1970–current) While the United States no longer has brick and mortar debtors' prisons, or "gaols for debtors" of private debts, the term "debtor's prison" in modern times sometimes refers to the practice of imprisoning indigent criminal defendants for matters related to either a fine or a fee imposed in criminal judgments. To what extent a debtor will actually be prosecuted varies from state to state. This modern use of the term debtors' prison arguably has its start with precedent rulings in 1970, 1971 and 1983 by the U.S. Supreme Court, and passage of the Bankruptcy Reform Act of 1978. In 1970, the Court ruled in Williams v. Illinois that extending a maximum prison term because a person is too poor to pay fines or court costs violates the right to equal protection under the Fourteenth Amendment. During 1971 in Tate v. Short, the Court found it unconstitutional to impose a fine