Won’t You Be My Neighbor?


What Returning Citizens Need to Make Successful Transitions

The fundamental building blocks for returning citizens’ successful transition back into society are, ironically, the most challenging for them to secure: steady employment, safe and affordable housing, and reliable transportation. If these three major needs are met, their chance of ending back behind bars is greatly reduced.

Employment, housing, and transportation are largely interrelated, as it is hard to have one without the other. For instance, it is difficult for a person to keep a job without having a place to live relatively nearby; it is doubtful a person can continue to pay rent without having a regular source of income; and it is challenging to find housing or commute to work without a reliable means of transportation. This catch-22 is what makes reentry so intimidating for those getting out of prison.

Won’t You Be My Neighbor?

Finding safe and affordable housing is a particularly perplexing issue for returning citizens. After leaving prison through parole, probation, or by maxing-out, their housing options are generally limited to living with family or friends, living at a transitional house, securing public housing, or renting. Each person’s circumstances determine their living situation.

For some, going to live with a family member is the best option, as it enables them to have a free place to live while trying to get back on their feet (that is, if there is another provider supporting them). For others, this is the worst place for them to go, as family members have been a poor influence on their lives and would further entrap them in a lifestyle of crime. Still, others may be in desperate circumstances and in need of public housing, while a few have the necessary means to rent an apartment or a house.

Potential Roadblocks: Affordability and Criminal Records

By far the biggest obstacle to obtaining housing is affordability. Many people leave prison owing various debts including child support arrearages, court fees, damages, restitution, etc. Faced with financial stress from multiple directions, many find it difficult to balance paying rent with any number of fees while trying to secure a job that pays a reasonable salary.

The other major hindrance that returning citizens face in obtaining housing is the impact of their criminal record. Many private leasing offices run background checks on prospective tenants, prohibiting those with a felony conviction from occupancy. Further, those who seek public housing run into the problem of Public Housing Authority’s limited capacity and multiple restrictions. Those who were evicted for drug-related criminal activity are banned from public housing for three years (unless they complete an approved rehabilitation program), while lifetime registered sex offenders and anyone convicted of manufacturing methamphetamines on public housing property are banned for life.

Housing Partnership Shows Some Success

As a means of overcoming some of these barriers, the State Board of Pardons and Paroles, the Department of Corrections, and the Department of Community of Affairs teamed up to form Reentry Partnership Housing (RPH). This program provides housing for people who have been authorized to parole but remain in prison due solely to having no residential options. For this group, the government pays approved housing providers $600 per month for three months which includes housing and food. Those who demonstrate the best outcomes receive the most parolees from the state.

The program has shown some success in alleviating the burden for hard-to-place parolees. “From 2002 to 2008, RPH placed 516 parolees, including 30% classified as special needs.” In addition, “Over 58% of participants secured employment…only 5% had their parole revoked and less than 3% absconded” (see Award-Winning Georgia Reentry Program).

While the program has had some success, one notable shortcoming is housing providers are often not located in the best cities for parolees to find jobs and establish roots. It is essential that returning citizens are placed in sufficiently resourced areas to aid in their successful transition; otherwise, the program becomes merely a short-term solution that leaves the person jobless and homeless after three months.

Identifying Housing Solutions

A potential remedy to this problem is to identify, facilitate, and fund housing providers in the cities where returning citizens are most likely to return. If people are placed in areas where they can find a job and have access to transportation, their chances of successfully transitioning into society are much higher.

The Governor’s Office of Transition, Support & Reentry (GOTSR) is making a considerate effort to identify and coordinate housing providers in the six reentry pilot sites that have been established across the state* (Albany, Atlanta, Augusta, Columbus, Macon, and Savannah).

GOTSR is in the process of implementing the new Georgia Prisoner Reentry Initiative (GA-PRI) Framework at these sites as a means of creating a seamless transition from prison to the community for those who will be released in these cities. The office is in the midst of hiring community coordinators, housing coordinators, employment coordinators, and prison in-reach specialists to aid in making this transition successful for returning citizens.

A big part of the work taking place at these sites involves identifying all of the resources in the local community that are available, assessing what resources are missing, encouraging service providers to work together and avoid duplicating efforts, and creating a database where returning citizens can easily access these resources. GOTSR launched a website earlier this year that contains the database where service providers can be found.

Undoubtedly, it will take the effort of local communities committed to meeting the needs of these men and women in order to see a tangible difference being made. However, if this sort of local involvement takes place throughout the state in conjunction with the efforts being made at the state level, who knows what sort of impact we will see in the lives of returning citizens over the next decade?


*Note: GOTSR does not provide funding for service providers in these communities but rather works to identify, coordinate, and galvanize these providers to effectively serve those returning to their communities from prison.

Minimizing Debt and Promoting Successful Reentry

Businessman walking through open door.jpg

This is the final entry in a series of posts highlighting GCO’s report, A High Price to Pay: Recommendations for Minimizing Debt’s Role in Driving Recidivism Rates. The first entry provided an overview of the report, the second entry laid out causes of debt for people reentering society from prison, and the third entry details the consequences of debt for returning citizens .This final post summarizes what has been said so far and outlines recommendations for the state to implement.

It is in the state’s interest and in the interest of justice for returning citizens[1] to pay debts and obligations owed to family members, victims, courts, and criminal justice agencies. Children need financial support from parents who have been incarcerated, victims ought to receive just compensation for losses and damages they have suffered, and courts and criminal justice agencies should be reimbursed for services that they provide. Nonetheless, for many people reentering society after a period of incarceration, debts and the inability to earn money while in prison create serious obstacles to a successful transition.

It is not uncommon for returning citizens to leave prison owing tens of thousands of dollars in child support arrears, restitution, court fines, fees, and surcharges to criminal justice agencies. Unrealistic terms for repaying these debts can discourage them from paying anything at all and encourages returning citizens to engage in the illegal, underground economy as a means of earning an income. Such actions result in probation or parole violations and may result in re-incarceration, the ultimate measure of recidivism.

Enforcing the repayment of debts and obligations without considering the needs and financial circumstances of returning citizens works contrary to the interests of all stakeholders involved. At least 95 percent of those who enter state prisons will return to society at some point, and these citizens often struggle to provide for their own basic needs upon release, much less service the debt they have incurred as a result of their conviction. Simply affording rent payments, buying food and clothing, and covering transportation expenses can be remarkably difficult for a person with a criminal record. The state needs to take this into consideration and set realistic terms for returning citizens to pay current obligations and repay debts, while at the same time establishing a reliable, coordinated, and systematic approach for the collection of money that is due. Such reform would increase the amount of money received by families, victims, courts, and criminal justice agencies, while decreasing the costs associated with recidivism.

The state of Georgia should consider implementing the following recommendations as a means of encouraging returning citizens to repay their debts and obligations while taking into consideration their need to be successfully reintegrated and reestablished within the community:

Identify offenders with child support involvement upon entry to prison

The state should identify offenders with child support responsibilities upon entry to prison by electronically matching the Georgia Department of Corrections (GDC) and Division of Child Support Services (DCSS) agency caseloads using common identifiers such as social security numbers and birth dates. This data match will allow the DCSS to provide pertinent information to incarcerated non-custodial parents concerning their child support obligation(s), as well as identify those who need to establish paternity and/or child support orders but have not already done so.

Provide child support information and services to parents during their incarceration

Once identified, the DCSS should inform incarcerated non-custodial parents of the amount of their child support obligation(s), notify them periodically of the amount their arrears have accrued, work with them to develop a plan for meeting these obligations upon release, and inform them of the incentives available to them through the state for consistent payment of support.

Provide a 90-day grace period to ease the transition phase

Upon release, the court and DCSS should automatically review the amount of child support returning citizens can pay on a case-by-case basis. Those who have no means of paying anything at that time should be given a grace period of 90 days before having to pay their obligations and repay debt. This grace period will provide them time to find a job, housing, transportation, and other essential needs that can enable them to meet their obligation. After the 90 days, those who still cannot pay their child support orders should be referred to the Georgia Fatherhood Program (GFP) or a Child Support Problem Solving Court (PSC) to receive additional help in finding a job and meeting their obligations.

Limit amount of wages to be garnished by the state

For returning citizens who have a job and are able to pay some amount of child support, the court should determine on a case-by-case basis the amount of wages to be garnished from their paycheck. The court should take into consideration such factors as the returning citizen’s income, cost of living, and other dependents that he or she is taking care of. The state should set a ceiling of 50 percent as the maximum percentage of wages to be withheld from a returning citizen – something which a third of the states have already done.

Forgive fines, fees, and surcharges owed to the state

The state should consider incentivizing returning citizens to pay child support and restitution by forgiving (or waiving) all or some of the fines, fees, and surcharges owed to the state for those who meet their monthly obligations. Forgiving these expenses in exchange for consistent payments would encourage greater compliance among returning citizens, which means that families and victims would receive more money in the long run. The state should tie participation in reparative activities as a condition for receiving these benefits, including drug treatment services, GFP, a PSC, or community service projects.

Reinstate driver’s licenses that were suspended for non-payment of child support

The state should lift driver’s license suspensions for returning citizens’ whose licenses were suspended because they were more than 60 days in arrears in making payments in full for current support, periodic payments on a support arrearage, or periodic payments on a reimbursement for public assistance. To maintain driving privileges, the state should require that returning citizens be actively seeking a job or actively working, and that they consistently pay child support according to their means.

Forgive arrears and interest owed to the state

The state should forgive arrears and interest owed to the state in order to motivate obligors to comply with long-term payment plans, to eliminate uncollectible debt, to facilitate case closure where appropriate, and to help families become more self-sufficient. To receive this benefit, the state should require that returning citizens make a set number of consecutive payments in exchange for a set percentage of arrears and interest owed to the state to be forgiven. Returning citizens should also have a determined minimum amount of arrears to participate in the debt compromise program.

Designate a single agency to track and consolidate returning citizens’ debts

One agency should be designated to track and consolidate individual returning citizens’ debts in a centralized tracking system and ensure that it remains updated as the person travels through the criminal justice system and is released into the community. This agency should be responsible for collecting all offense-related debt and disbursing funds according to the priority set by the federal and state government.[2] Regular updates concerning the total amount of debt owed and expected dates and amounts of repayment should be sent to returning citizens, victims, courts, and criminal justice agencies. Courts and criminal justice agencies should use this information to establish realistic repayment plans for returning citizens based on their financial situation.



[1] We realize that some will be frustrated by our use of the term “returning citizen” in this report and would prefer to see us use a more familiar term such as “ex-offender.” Our use of the term “returning citizen” is intended not as a political statement but as an acknowledgement that almost all offenders will return to our community at some point in the future and that it is in our best interest to think of offenders in that light, as our thinking will shape how we treat them during incarceration and what we expect of them upon release.

[2] Offense-related debt does not include child support, which is collected and tracked by DCSS and cannot be consolidated with restitution, fines, fees, and surcharges. Nonetheless, the amount of child support that has been collected should also be tracked by the agency that is consolidating offense-related debts, because the amount that goes toward child support (which must be paid first in priority according to federal law) impacts the amount that can be paid toward these other debts.


To view the endnotes included within the recommendations section of the report, please click here.


***Edit to the report: May 6, 2015

At the time of writing the report, the author was unaware that Georgia already has a detailed debt reduction program in place to assist indigent non-custodial parents who owe arrears to the state. The Division of Child Support Services’ (DCSS) State Debt Reduction Program (SDRP) provides non-custodial parents the ability to have a significant percentage of their state-owed arrears reduced if an agent determines that:

(1) “Good cause” existed for the nonpayment of the public assistance debt;

(2) Repayment or enforcement of the debt would result in substantial and unreasonable hardship for the parent owing the debt;

(3) The non-custodial parent is currently unable to pay the debt;

(4) The non-custodial parent is making regular payments of current child support, regardless of the amount.

The amount that eligible non-custodial parents can have their arrears reduced depends upon the amount they owe. Those with a greater amount of arrears owed to the state are eligible to have a greater percentage reduced (with the exception of those who owe less than $100, who can have their entire state-owed arrears balance waived). For example, non-custodial parents with state-owed arrears balances of $9,000 or greater can have their arrears waved or reduced by 75 percent, so long as they pay the remaining 25 percent owed in a lump sum payment or in 24 monthly installments.[i]

While Georgia has a detailed debt reduction program in place, it appears that the participation in the program is limited. In 2014, only 349 out of the 354,427 total non-custodial parents ordered to pay child support in Georgia entered into the plan, based on the 30 DCSS offices that reported.[ii]* More should be done to enroll struggling returning citizens with child support arrears owed to the state into the program. One way the state can do this is by promoting it within the Fatherhood Program and Child Support Problem Solving Courts (PSCs), which returning citizens will be likely to participate in.


[i] Division of Child Support Services, “State Debt Reduction Guidelines,” Employee Reference Guide – Standard Operating Procedure 251, Email Release May 24, 2013.

[ii] Erica Thornton, Manager of the Policy and Paternity Unit, Division of Child Support Services, Georgia Department of Human Services, email message to author, February 3, 2015; Georgia Department of Human Services, “Division of Child Support Services: Fact Sheet,” Revised November 2014.

*While not all 354,427 non-custodial parents ordered to pay child support in Georgia owe arrears to the state, the large figure suggests that there may be numerous non-custodial parents (particularly those reentering society from prison) who do (or should) qualify for the program, but are currently being overlooked.

Why Do People Leave Prison with So Much Debt?

Stacks of Coins

This is the second entry in a series of posts highlighting GCO’s report, A High Price to Pay: Recommendations for Minimizing Debt’s Role in Driving Recidivism Rates. The first entry provided an overview of the report, as well as a recent update to one of the recommendations.

Returning citizens often face a mountain of debt upon leaving prison that makes it more difficult to successfully reenter society. Some of this debt may have existed prior to incarceration – such as consumer debt and child support – while much of it arises as a direct result of a criminal conviction, and is made much worse by subsequent incarceration and unemployment. Studies have shown average debt amounts in certain jurisdictions to be as high as $20,000 in child support arrears[i] and between $500 and $2,000 in offense-related debt.[ii] This onerous amount of debt, combined with the lack of opportunity to earn or save money while in prison, cause many offenders to reenter society with little hope of being able to repay what they owe.

Consumer Debt

It is common for people who are incarcerated to carry some level of consumer debt into prison, whether it is from outstanding mortgages, car loans, school loans, or credit cards.[iii] Missed payments on these mortgages, loans, and bills result in back interest, fees, and fines accumulating over the course of a person’s incarceration. The end result can be the offender accumulating an unmanageable amount of debt by the time he or she is released, leading him or her to file for bankruptcy.[iv]

Child Support

Child support typically comprises the largest debt returning citizens owe,[v] as non-custodial parents who are unable to modify their orders during incarceration can owe tens of thousands of dollars in arrears by the time they are released.[vi]

One study examining Massachusetts’ inmates and parolees revealed that non-custodial parents entering prison owed an average of $10,543 in unpaid child support and were likely to generate an additional $10,000 in arrears by the time they were released.[vii] More startlingly, one-fifth of the state inmates were estimated to generate arrears balances in excess of $30,000 while in prison.[viii] Another study of 350 parolees in Colorado demonstrated that they had an average balance of $16,651 in arrears.[ix]

Many returning citizens in Georgia are likely to be impacted by child support debt, as 60 percent of offenders in Georgia self-report having one or more children upon entering prison.[x] Accepting the circumstances of the incarcerated, some states allow offenders to modify their child support while in prison to avoid the accrual of arrears. However, Georgia offenders are prohibited from modifying their arrears while incarcerated, as the state deems incarceration to be a form of “voluntary unemployment.”[xi] As such, there is no mechanism for indigent offenders in Georgia to avoid accruing child support debt.

Once child support arrears have accrued, federal law requires non-custodial parents to pay the full amount owed to custodial parents, even if modification of orders is granted upon release from prison.[xii] However, federal law does permit arrears owed to the state to be forgiven retroactively. Child support arrears become owed to the state when the Department of Human Resources supplies Temporary Assistance for Needy Families (TANF) to custodial parents who are not receiving requisite child support payments from non-custodial parents. Once funds are distributed, the non-custodial parent becomes obligated to repay the state for supplying the amount of assistance he or she was originally responsible for paying the custodial parent.[xiii]


Another source of debt which many returning citizens owe upon reentry is payment of restitution to victims. The amount of restitution owed by offenders usually ranges from several hundreds of dollars to several thousands of dollars, depending on the offense.[xiv] Restitution provides a way for offenders to pay for financial loss and other damages suffered by victims including lost property, medical expenses, costs of counseling, funeral and burial expenses, and lost wages.[xv] It also serves as a way for the offender and the state to demonstrate that they recognize the harm that the victim suffered and the offender’s obligation to make amends.[xvi] One study conducted in Pennsylvania found that paying restitution is related to lower recidivism.[xvii] As such, it is an important obligation for returning citizens to pay.

However, problems occur when a person’s financial status and earning capacity is not considered in forming restitution orders.[xviii] This can result in unrealistic terms of repayment being formed, which, combined with other court-imposed financial obligations, create a financial burden for the returning citizen and may discourage him or her from repaying anything at all.[xix] When this situation happens, it leaves victims without compensation for financial loss or damages and diminishes their confidence in the criminal justice system.

In Georgia, the Crime Victims Restitution Act of 2005 mandates that offenders make restitution payments to victims while under parole supervision.[xx] The court determines the amount of restitution and manner of paying it during sentencing, and parole officers are responsible for facilitating and monitoring payment compliance once the offender is in the community. Parolees must begin paying restitution upon release and are required to pay a minimum of $30 per month. [1],[xxi]

Fees, Fines, and Surcharges

A third source of debt that encumbers returning citizens is fees, fines, and surcharges that arise as a direct result of a criminal conviction.

Fees are amounts charged to offenders in exchange for the services provided by courts, probation departments, parole supervision, and other agencies.[xxii] For example, the Georgia State Board of Pardons and Paroles collects a monthly supervision fee of $30 from every parolee with a supervision period of three months or longer. [2],[xxiii]

Fines imposed by the court are intended to punish offenders and deter others from committing such crimes.[xxiv] The amount of the fine varies based on the person’s charge and can be mandatory or discretionary.[xxv] A fine for a third DUI offense in Georgia, for instance, can be as high as $5,000.[xxvi]

Finally, surcharges are add-on amounts often unrelated to the crime but used to generate revenue for criminal justice agencies.[xxvii] Revenue is designated toward such things as retirement funds for sheriffs and peace officers, law enforcement facilities and training, indigent defense programs, and education and treatment programs.[xxviii] While small in isolation, surcharges can total hundreds and even thousands of dollars.[xxix]

Georgia began collecting surcharges in 1950 when the legislature passed a statute requiring a deduction to be taken from every criminal fine to support the Peace Officers’ Annuity and Benefit Fund. By 2001, the number of court-imposed surcharges had risen to 21 to support nine state programs, five local programs, and the State General Fund.[xxx] Surcharges range from $0.50 per case to 50 percent of the total fine amount.[xxxi]

Inability to Earn or Save Money in Prison

A fourth reason returning citizens in Georgia have difficulty repaying debts upon release is that they do not have the ability to earn money for their work performed while incarcerated.[xxxii] As one of only three states that do not pay inmates for work,[3][xxxiii] Georgia bars those who are indigent from being able to meet current obligations, pay-down debt, or save for their inevitable reentry while in prison. This policy removes a strong incentive for them to work and develop skills and experience that will be helpful in obtaining a job upon release.


Without having a realistic plan and payment options to pay-off all of this debt, people returning from prison are less likely to pay anything at all, more likely to engage in the underground economy to avoid wage garnishment, and more likely to make bad decisions that may result in re-incarceration. The consequences of debt can be detrimental for returning citizens.



[1] Payment is required upon release for parolees serving 90 days or more under parole supervision.

[2] Parolees serving for violent offenses pay a monthly victim compensation fee of $30 in lieu of the supervision fee.

[3] Georgia inmates who participate in the Prison Industry Enhancement Certification Program (PIECP) and inmates who are placed in a transitional center are the exception, as they do have a chance to earn money while incarcerated. However, PIECP is limited to two prisons – though the state has plans to expand it to three to five more prisons – and there are only 13 transitional centers across the state serving 2,674 of 53,558 inmates . The other two states who do not pay inmates for work are Arkansas and Texas.



Some of the citations listed below are abbreviated. To view the full citation, see the “Notes” section in our report, A High Price to Pay.

[i] Nancy Thoennes, Child Support Profile: Massachusetts Incarcerated and Paroled Parents, Center for Policy Research, May 2002, 26, http://cntrpolres.qwestoffice.net/reports/profile%20of%20CS%20among%20incarcerated%20&%20paroled%20parents.pdf.

[ii] Carl Reynolds et al., A Framework to Improve How Fines, Fees, Restitution, and Child Support are Assessed and Collected from People Convicted of Crimes, Council of State Governments Justice Center and the Texas Office of Court Administration, Interim Report, March 2, 2009, 8, http://csgjusticecenter.org/wp-content/uploads/2013/07/2009-CSG-TXOCA-report.pdf.

[iii] Erica Sandberg, “Ex-offenders face big debt challenges after prison,” CreditCards.com, August 30, 2010, accessed May 8, 2014, para. 7, http://www.creditcards.com/credit-card-news/ex-offenders-felons-prisoners-jail-in-debt-1264.php.

[iv] Connie Prater, “How to prepare financially for time in prison,” CreditCards.com, October 15, 2010, accessed March 26, 2014, para. 7, http://www.creditcards.com/credit-card-news/how-to-prepare-inmate-financially-jail-prison-1265.php.

[v] Carl Reynolds et al., A Framework to Improve, 10.

[vi] Nancy Thoennes, Child Support Profile, 18.

[vii] Ibid., 26.

[viii] Ibid.

[ix] Jessica Pearson, “Building Debt While Doing Time: Child Support and Incarceration,” Judge’s Journal 43 (2004): 7; Jessica Pearson and Lanae Davis, Serving Parents Who Leave Prison: Final Report on the Work and Family Center, Center for Policy Research, 2001, ii, http://www.hawaii.edu/hivandaids/Serving%20Parents%20Who%20Leave%20Prison.pdf.

[x] Georgia Department of Corrections, Inmate Statistical Profile, 8.

[xi] Office of Child Support Enforcement, “Project to Avoid Increasing Delinquencies: ’Voluntary Unemployment,’ Imputed Income, and Modification Laws and Policies for Incarcerated Noncustodial Parents,” U.S. Department of Health and Human Services, July 2012, 4, http://www.acf.hhs.gov/sites/default/files/programs/css/paid_no_4_companion.pdf; See O.C.G.A. § 19-6-15(j).

[xii] Jessica Pearson, “Building Debt,” 5.

[xiii] Rachel L. McLean and Michael D. Thompson, Repaying Debts, Council of State Governments Justice Center, 2007, 26, http://csgjusticecenter.org/wp-content/uploads/2012/12/repaying_debts_full_report-2.pdf.

[xiv] Judge Brian Amero, Henry County Superior Court, telephone conversation with author, May 29, 2014.

[xv] National Center for Victims of Crime, “Restitution Procedures,” in Promising Practices and Strategies for Victim Services in Corrections, 1997, http://www.victimsofcrime.org/library/publications/archive/promising-practices-and-strategies-for-victim-services-in-corrections; National Center for Victims of Crime, Making Restitution Real: Five Case Studies on Improving Restitution Collection, 2011, 3, 4, http://csgjusticecenter.org/wp-content/uploads/2011/11/2011-Natl-Center-for-Victims-of-Crime-report.pdf.

[xvi] National Center for Victims of Crime, Making Restitution Real, 4.

[xvii] R. Barry Ruback, Restitution in Pennsylvania: A Multimethod Investigation, Submitted to Pennsylvania Commission on Crime and Delinquency, Final Grant Report, August 2002, 9, 98, https://www.ncjrs.gov/pdffiles1/Archive/221282NCJRS.pdf.

[xviii] National Institute of Justice, “Restitution,” Archived material that is the product of five regional symposia held on restorative justice between June 1997 and January 1998, accessed April 9, 2014, para. 5, http://nij.gov/topics/courts/restorative-justice/promising-practices/Pages/restitution.aspx.

[xix] Carl Reynolds et al., A Framework to Improve, 1.

[xx] Georgia State Board of Pardons and Paroles, “Restitution,” accessed April 10, 2014, http://pap.georgia.gov/restitution.

[xxi] Ibid.

[xxii] Rachel L. McLean and Michael D. Thompson, Repaying Debts, 2; Georgia State Board of Pardons and Paroles, “Supervision & Victim Fees,” accessed April 10, 2014, http://pap.georgia.gov/supervision-victim-fees.

[xxiii] Georgia State Board of Pardons and Paroles, “Supervision & Victim Fees,” accessed May 12, 2014, http://pap.georgia.gov/supervision-victim-fees.

[xxiv] Paul Peterson, “Supervision Fees: State Policies and Practices,” Federal Probation 76 (2012): para. 2, http://www.uscourts.gov/uscourts/FederalCourts/PPS/Fedprob/2012-06/supervision.html.

[xxv] Rachel L. McLean and Michael D. Thompson, Repaying Debts, 2.

[xxvi] O.C.G.A. § 40-6-391.

[xxvii] Rachel L. McLean and Michael D. Thompson, Repaying Debts, 2.

[xxviii] Administrative Office of the Courts, Court Fees in Georgia – Laws and Information, Court Business and Process Improvement Program, October 2004, 5, http://www.georgiacourts.org/aoc/publications/courtfeesbook10_2004.pdf.

[xxix] Alicia Bannon, Mitali Nagrecha, and Rebekah Diller, Criminal Justice Debt: A Barrier to Reentry, Brennan Center for Justice, New York University School of Law, 2010, 1, http://www.brennancenter.org/sites/default/files/legacy/Fees%20and%20Fines%20FINAL.pdf.

[xxx] Russell W. Hinton, “Court Fees,” Department of Audits and Accounts, Performance Audit Operations Division, October 2001, 1. This executive summary can be found in the following report: Administrative Office of the Courts of Georgia, Municipal Court Fee Study, November 2003, Appendix A-1, http://www.georgiacourts.org/aoc/publications/municipal_court.pdf.

[xxxi] Ibid.

[xxxii] Adam Crisp, “Georgia inmates strike in fight for pay,” timesfreepress.com, December 14, 2010, accessed May 20, 2014, http://www.timesfreepress.com/news/2010/dec/14/georgia-inmates-strike-in-fight-for-pay/?local.

[xxxiii] Cindy Upton and Sarah Harp, Cost of Incarcerating Adult Felons, Kentucky Legislative Research Commission, Program Review and Investigations Committee, Research Report No. 373, 45, http://www.lrc.ky.gov/lrcpubs/RR373.pdf; A.J. Sabree, Strategic Planning and Implementation Consultant for the Georgia Department of Juvenile Justice, email message to author, June 5, 2014; Peter Wagner, “Section III: The Prison Economy,” in The Prison Index: Taking the Pulse of the Crime Control Industry, Western Prison Project and the Prison Policy Initiative, April 2003, 130-131, http://www.prisonpolicy.org/prisonindex/prisonlabor.html; Adam Crisp, “Georgia inmates strike in fight for pay,” timesfreepress.com, December 14, 2010, http://www.timesfreepress.com/news/2010/dec/14/georgia-inmates-strike-in-fight-for-pay/?local.