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 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.