Since the late 20th century, the term "debtors' prison" has also sometimes been applied by critics to criminal justice systems in which a court can sentence someone to prison over willfully unpaid criminal fees, usually following the order of a judge. For example, in some jurisdictions within the United States, people can be held in contempt of court and jailed after willful non-payment of child support, garnishments, confiscations, fines, or back taxes. Additionally, though properly served civil duties over private debts in nations such as the United States will merely result in a default judgment being rendered "in absentia" if the defendant willfully declines to appear by law, a substantial number of indigent debtors are legally incarcerated for the crime of failing to appear at civil debt proceedings as ordered by a judge. In this case, the crime is not indigence, but disobeying the judge's order to appear before the court. Critics argue that the "willful" terminology is subject to individual "mens rea" determination by a judge, rather than statute, and that since this presents the potential for judges to incarcerate legitimately indigent individuals, it amounts to a de facto "debtors' prison" system.