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One of the most distinctive features of the criminal justice system in the United States is the large number of individuals incarcerated in its prisons and jails. Since the early 1970s, the United States has experienced approximately 40 years of nearly uninterrupted growth in prison and jail populations. There were approximately 1.6 million people incarcerated in state and federal prisons, and approximately 750,000 individuals were held in county jails in 2010 (Minton 2011). Only in recent years has the growth in incarceration slowed.

Incarceration rates in the United States are several times greater in magnitude than those of other advanced Western democracies. A variety of explanations have been proposed for why incarceration is so much greater in the United States than in similarly developed nations. Some suggest that the United States has much greater levels of crime than in other Western democracies, while others argue that a “tough on crime” movement that has increased penalties is responsible for this growth. Research tends to indicate that the high rates of incarceration are mostly due to differences in sentencing policies and practices and not to exceptionally high levels of crime.

Further evidence that policy changes can have a significant impact on incarceration rates can be found by examining the experience of other countries. In the early 1950s, Finland had an incarceration rate several times greater than that of its Nordic neighbors. A profound shift in the thinking about the use of incarceration led to a series of changes to sentencing practices in Finland. As a result of these changes, Finland has gradually reduced its incarceration rate over the past 50 years and now has one of the lowest incarceration rates in all of Europe. Germany is another nation that has controlled prison population growth through policy changes. The experience of Germany and Finland in controlling growth in incarceration suggests that changes to current sentencing practices in the United States can be effective at reducing prison populations.

Incarceration Rates In The United States And Other Western Democracies

The United States incarcerates more of its population than any other country in the world. Despite being home to just 5 % of the global population, the United States incarcerates about 25 % of the world’s prisoners (Walmsley 2009). At year-end 2010, there were more than 1.6 million prisoners in US federal and state prisons for a rate of 497 prison inmates per 100,000 US residents (Guerino et al. 2011). As of midyear 2010, there were nearly 750,000 inmates held in local jails for a rate of 248 jail inmates per 100,000 US residents (Minton 2011). These rates are slightly down from their peaks in 2007 when prison and jail incarceration rates were 506 and 259, respectively. When prison and jail inmates are combined, the incarceration rate in the United States at year-end 2010 was approximately 730 inmates per 100,000 US residents (International Centre for Prison Studies nd).

The current level of incarceration in the United States is exceptional by both historical and comparative standards. Current levels of incarceration in the United States are the highest they have ever been in history. Throughout most of the twentieth century, incarceration rates in the United States remained relatively stable at a level of approximately 100 inmates per 100,000 US residents – a rate comparable to those of other Western democracies at the time. The stability of incarceration levels in the United States led Blumstein and Cohen (1973) to theorize that societies maintain stable levels of punishment. The theory did not gain much traction, however, as incarceration rates began nearly four decades of continuous growth almost simultaneous to the publication of the stability of punishment hypothesis.

Incarceration rates in the United States are also exceptional in comparison with other nations. The United States has the highest prison population rate in the world according to the International Centre for Prison Studies. In 2010, the nations that came closest to the level of incarceration in the United States are Rwanda, Georgia, and Russia. Drawing comparisons between these nations and the United States, however, would be misguided as these nations differ along a number of different dimensions such as levels of economic and social development. When one compares the United States to nations that are more similar in terms of economic and social development, however, the difference in incarceration rates is even greater. Incarceration rates of advanced Western democracies such as England, Germany, the Netherlands, Sweden, and Australia are considerably smaller.

While the United States has an exceptionally high incarceration rate relative to other advanced Western democracies, it is not the only nation that has experienced increases in incarceration rates in recent history (International Centre for Prison Studies nd). Incarceration rates in the nations of England and Wales, Scotland, and Australia increased by approximately 50 % between 1992 and 2010, while Netherland’s incarceration rate has nearly doubled during that time. Only a few nations have managed to reduce or maintain relatively stable incarceration rates as Finland and Germany have done. Between 1992 and 2010, Finland’s prison population rate has dropped by more than 10 %. Germany did experience an increase in incarceration since 1992; however, there has been a recent downward trend since 2004.

Explaining Cross-National Differences In Incarceration Rates

It is important to first acknowledge the difficulty inherent in making comparisons between nations in terms of incarceration use. Differences observed between nations in incarceration may be an artifact of different recording and reporting practices rather than a real substantive difference. One important difference between nations is the determination of who is included in the calculation of the incarcerated population. Some nations may include jail inmates in their calculation of their incarceration rates while other nations may exclude jail inmates. The determination of who should be counted as a prisoner can have a substantial impact depending on the size of the jail population.

With this caveat in mind, there is a relatively small body of literature that has examined and sought to explain cross-national differences in incarceration rates. This research has investigated the relationship between incarceration rates and a variety of social, political, and economic factors. Findings regarding which factors affect incarceration rates have been somewhat inconsistent due to methodological differences between studies. For instance, some studies draw comparisons between a large number of countries which differ from each other along a number of dimensions, while others focus on a smaller number of countries that are more comparable in terms of economic and social development. It is important to keep this in mind as making comparisons between vastly different nations may lead one to draw erroneous conclusions.

The factor most often thought to affect incarceration rates are crime rates. Homicide rates in the United States are about as twice as high as those of other advanced Western democracies, such as Finland, which has one of the highest homicide rates in Western Europe (United Nations Office on Drugs and Crime 2011). However, homicide accounts for a very small proportion of total crime and should not have a very large impact on incarceration rates. Other than homicide, crime and victimization rates in the United States are not significantly different from those of other advanced Western democracies (Farrington et al. 2004; Van Dijk et al. 2007).

Few studies have found support for the notion that differences in crime rates can account for disparities in incarceration rates (Lynch 1988; Neapolitan 2001). Neapolitan (2001) found a significant relationship between homicide rates and imprisonment rates in his study of 148 nations. Lynch (1988) also found differences in incarceration rates between the United States, England, Canada, and West Germany could be explained in large part by differences in the levels and types of crime in these nations.

Most research has found, however, that crime rates are not directly associated with incarceration rates (Young and Brown 1993; Lappi-Seppala 2007). Incarceration rates and crime rates in the United States have moved independently since the early 1970s. Incarceration rates have been increasing in the United States since the early 1970s regardless of changes in crime rates. Despite similarities in crime trends since 1960, Canada has maintained a relatively stable incarceration rate while the United States experienced its incarceration boom (Doob and Webster 2006).

It is more probable that crime rates indirectly affect incarceration rates by affecting attitudes toward punishment among politicians and the general public. Rising crime rates may contribute to increased punitive attitudes and increasingly severe criminal penalties that would result in increased use of incarceration. This may explain the divergent trends in incarceration between the United States and Canada. Doob and Webster (2006) attribute Canada’s stable incarceration trend since the 1960s to the lack of changes in sentencing practices despite increasing crime rates. In contrast, the indeterminate sentencing scheme used in the United States came under fire from a number of different fronts in the 1970s. The Martinson (1972) report, which claimed nothing works in rehabilitation, and Judge Marvin Frankel’s (1973) criticism of indeterminate sentencing contributed to profound changes in sentencing practices in the United States including the adoption of determinate sentencing, mandatory minimums, habitual offender laws, and the reduction or elimination of parole (MacKenzie 2006).

There is good evidence that suggests these changes to sentencing and correctional policies were largely responsible for incarceration growth in the United States. Blumstein and Beck (1999) attribute 88 % of the increase in imprisonment in the United States between 1980 and 1996 to changes in sentencing practices. During this time, there was an increase in both the number of offenses for which one may be imprisoned and in the length of prison time served.

The type of legal system used in a country is another factor that can affect incarceration rates. Ruddell (2005) and DeMichele (2010) found the common-law legal system used in the United States and other Anglo nations to be associated with significantly higher incarceration rates than nations that operate under a system of Romano-Germanic or Nordic law. Incarceration rates tend to be low under Nordic law regimes (e.g., Finland) and moderate under Romano-Germanic law legal regimes (e.g., Germany). DeMichele (2010) attributes the difference in incarceration rates between legal regimes to several factors including the balance of power among the courtroom workgroup, differences in courtroom practices (e.g., trial structure), and the involvement of lay participants in the judicial process.

Certain aspects of the common-law legal regime, such as the jury trial, increase the involvement of lay participants in making decisions regarding punishment. Heinous crimes that receive heavy media coverage may result in public demands for increasing the severity of punishment. Jacobs and Kleban (2003) found higher incarceration rates occur in nations where the general public has the greatest influence over corrections decisions. The lowest incarceration rates were found in nations where decisions about corrections were made by unelected experts, e.g., judges.

Another political factor that may affect incarceration rates is the level of conservative political strength. Studies done in the United States tend to find a relationship between conservative political strength and incarceration (Sutton 2000; Jacobs and Helms 1996). However, comparative cross-national research has not found this relationship to be significant (Jacobs and Kleban 2003). Jacobs and Kleban (2003) speculate that the failure to find this relationship in other advanced democracies may reflect the fact that decisions about corrections are insulated from popular opinion.

Economic factors provide another potential explanation for differences in national incarceration rates. However, research has failed to find a clear association between economic factors and incarceration. Ruddell (2005) found no relationship between incarceration rates and income inequality, unemployment, or inflation in a sample composed of the richest 100 nations as determined by GDP. Jacobs and Kleban (2003) also fail to find a relationship between incarceration and unemployment. However, they find that the most economically developed nations with the highest per capita GDP are more likely to have higher proportions of their population in prison. Incarceration rates in these nations may simply be higher because they have more resources to build and stock prisons.

Incarceration rates may also be affected by structural factors of the economic system. Sutton (2004) found a relationship between incarceration rates and unemployment, inflation, and income inequality in a study of 15 affluent capitalist democracies. However, the relationship between incarceration rates and these factors disappeared when measures of institutional structure, such as union and left party strength, are considered. Other factors that may affect incarceration rates include out-of-wedlock birthrates (Jacobs and Kleban 2003) and the degree of population heterogeneity in a nation (Jacobs and Kleban 2003; Ruddell 2005).

In sum, there are a variety of social, cultural, and economic factors that account for the disparity in incarceration rates between the United States and other advanced Western democracies. There is mixed evidence that suggests incarceration rates are related to crime rates or economic factors such as unemployment or inequality. Instead, there is a good body of research that suggests incarceration rates are affected by changes in criminal justice policies and the type of legal system used in a nation. Further evidence that changes to criminal justice policies can have a significant impact on incarceration rates will be presented in the next section.

Controlling Prison Population Growth

It is clear that changes to criminal justice policies and practices can have a significant impact on incarceration rates. The operation of the criminal justice system in the United States underwent profound changes in the early 1970s that contributed to incarceration growth. These changes include the switch to a determinate sentencing system, the adoption of mandatory minimums and habitual offender laws, and truth-insentencing legislation. Combined, these policies have increased the number of offenses for which one could be imprisoned and increased the amount of time offenders serve in prison.

If these policy changes were responsible for the growth in incarceration, then it is important to ask whether policy changes could reverse the past 40 years of incarceration growth in the United States. The answer to this question may be found by examining the experience of other nations that have dealt with extraordinarily high incarceration rates. In particular, Finland’s experience with incarceration could serve as a guide for how incarcerated populations in the United States might be reduced.

In the early 1950s, the incarceration rate in Finland was around 200 prisoners per 100,000 inhabitants. While this rate is a fraction of the current imprisonment rate in the United States, at the time it was nearly twice the rate in the United States and was three to four times greater than other Nordic countries. Lappi-Seppala (2001) identified three possible factors that explained Finland’s exceptionally high incarceration rate at that time. These factors include (1) a unique “cultural climate in which severity was not measured on the same scale used in the other Nordic countries” (106), (2) a rigid penal system characterized by high minimum penalties, and (3) severe sentencing practices for relatively common crimes such as drinking and driving.

These three factors also seem characteristic of criminal justice practices in the United States today. Criminal sentences in the United States tend to be more severe than those of other advanced Western democracies, and the greatest disparities in punishment exist among less serious property crimes. In a comparison of punitiveness among eight advanced Western democracies, Blumstein, Tonry, and Van Ness (2005) find that offenders convicted in the United States between 1980 and 1999 served considerably longer periods of time in prison than did offenders who were convicted in other countries. Further, they find the disparity in time served between the United States and other nations is greatest for less serious crimes such as motor vehicle theft. Lynch (1993) had previously found that average sentence lengths in the United States in the 1980s were considerably longer than those in Australia, Canada, England and Wales, and West Germany. However, the amount of time served was relatively similar for violent crimes in these five nations. Prisoners serving sentences for property crimes in the United States spent more time in custody than those in Australia, Canada, and England and Wales.

Changes in these three factors were responsible for the gradual decarceration that took place in Finland since the mid-1950s (Lappi-Seppala 2001). At the time, there was a profound shift in the ideological thinking of criminal justice policy which had till then emphasized (coercive) rehabilitation of offenders. Unlike the movement against rehabilitation in the United States where the punishment philosophy was replaced by the goals of incapacitation and deterrence, the backlash against rehabilitation in Finland was replaced by a philosophy of restitution that emphasized (1) the minimization of costs of crime and crime control to society and (2) creating a fair distribution of costs among the offender, society, and the victim. Rather than serving as the primary instrument of criminal punishment, incarceration was seen to be one possible option among others. This change in philosophy was accompanied by the recognition that the most effective crime prevention may not occur through fear of punishment (deterrence) but rather through increasing the legitimacy of the law and subsequently enhancing the internalization of values and morality.

This change in philosophy and the inability to justify the exceptionally high rates of incarceration in Finland relative to other Nordic countries prompted a series of legislative and policy reforms that would ultimately reduce incarceration levels in Finland. These reforms included reduced penalties for several common crimes, the expanded use of noncustodial alternatives, and the development of sentencing alternatives specifically designed to reduce the number of offenders sentenced to imprisonment. A complete discussion of these reforms can be found in Lappi-Seppala (2001) and Tornudd (1993).

Reduction of penalties for theft and drunk-driving offenses were two reforms that had a significant impact in reducing the number of offenders in Finnish prisons (Lappi-Seppala 2001). These reforms were designed to both (1) reduce the proportion of convicted offenders who would receive a custodial sentence and (2) reduce the sentence lengths of those who were incarcerated. Through a legislative reformenacted in 1972 that redefined serious forms of theft and introduced a new penalty range, the percentage of convicted offenders who received a custodial sentence for theft dropped from 38 % in 1971 to 11 % in 1991. In addition, the median sentence for offenders convicted of larceny dropped from 7.4 months in 1971 to 2.6 months in 1991. Reforms pertaining to drunk-driving offenses focused on replacing custodial sentences with noncustodial alternatives such as community service. Similar to the success of the reforms directed at theft offenses, drunk-driving-related reforms reduced the percentage of convicted offenders sentenced to unconditional imprisonment from 70 % in 1971 to 12 % in 1981.

The expanded use of noncustodial alternatives was another major reform that contributed to reduced incarceration rates in Finland. Specifically, Finland has relied heavily on the use of community service as an alternative for short terms of imprisonment Lappi-Seppala 2004. This alternative was effective at reducing incarceration because it was specifically designed to ensure that the only offenders who would receive it would be those destined for incarceration. While sentencing alternatives have been used in the United States, they have not been very effective at reducing the use of incarceration as a punishment. Instead of diverting convicted offenders from custodial sentences, the use of sentencing alternatives in the United States has contributed to a “net-widening” effect since those offenders receiving sentencing alternatives would not be incarcerated otherwise.

Finland adopted a two-step procedure during the sentencing phase to ensure that only those who were going to initially receive a custodial sentence were eligible for the community service alternative (Lappi-Seppala 2004). In the first step, the court determines a sentence for the offender using the normal criteria for sentencing. If the offender is sentenced to unconditional imprisonment, then the court can decide whether to commute the sentence into community service provided a number of criteria have been met. These criteria include (1) the consent of the convicted person, (2) the determination that the convicted offender is able to carry out the requirements, and (3) that there is nothing in the prior criminal history of the convicted person that would preclude the use of community service (e.g., violent history). After several years of being implemented on an experimental basis, community service orders started being used nationwide in 1994. An examination of trends in Finnish court sentencing practices suggests that community service orders, used in this way, have been successful in reducing the flow of offenders into prison. Since 1994, approximately 30 % of convicted offenders sentenced to an unconditional prison sentence have received a community service order instead.

Even as Finland took these steps to reduce its incarceration rate, crime trends in Finland were remarkably similar to those of its Nordic neighbors (Falck et al. 2003). Crime rates in Finland, Norway, Sweden, and Denmark increased from the 1960s through the early 1990s when they reached a more stable trend. While the increase in crime in Finland was unremarkable when compared to its neighbors during this time, the decline in incarceration rates during this same period was exceptional. In 1950, the incarceration rate in Finland was 187 inmates per 100,000 population. By the late 1990s, the incarceration rate in Finland dropped below 60 – a level comparable to those of its neighbors. Incarceration rates in Finland have since increased; however, all of the Nordic nations have experienced similar increases (National Research Institute of Legal Policy 2011).

Germany is another nation that has taken measures to control the growth of incarceration at a time when crime rates were increasing. Although Germany has not experienced as high of an incarceration rate as has Finland, it has faced problems related to the heavy use of incarceration such as severe overcrowding (Graham 1990). Heinz (2006) traces the history of sentencing practices in Germany as far back as 1882, where nearly 80 % of convicted offenders were sentenced to unconditional prison sentences. Since then, Germany has gradually rolled back its use of custodial sentences in favor of noncustodial alternatives such as fines. Since the mid-1980s, less than 10 % of convicted offenders in German courts have received unconditional prison sentences, while approximately 70 % of offenders were ordered to pay fines.

While the use of imprisonment has declined throughout the twentieth century, modern sentencing practices in Germany can be traced back to legislation enacted in 1969 (Weigend 2001). The criminal law reforms that took effect in 1969 were explicitly designed to restrict the use of imprisonment to only the most serious cases. This aim was to be achieved through several measures including (1) the abolishment of prison sentences of less than 1 month; (2) the decriminalization of many petty offenses, such as public order and traffic offenses, which were subsequently turned into administrative infractions punishable by fines only; and (3) the discouragement of sentences of less than 6 months. Noncustodial alternatives, primarily fines and probation, were used in lieu of short terms of imprisonment.

The criminal law reforms of 1969 also began a trend in the development of sanctions other than those that have been traditionally used, i.e., imprisonment, probation, and fines (Weigend 2001). Some of these alternative sanctions have not been used very often, such as warning with suspension, while others are being increasingly used by the German courts, such as community service and restitution programs. Not all of these additional sanctions are directed at reducing the number of convicted offenders sentenced to imprisonment. For example, the sanction “warning with suspension of punishment” allows courts to suspend punishments consisting of dayfines and sentence the offender to probation instead. On the other hand, legislation enacted in 1994 allows the courts to mitigate the penalty or suspend sentences of less than 1 year of imprisonment if the convicted offender either participates in a victim-offender reconciliation program or makes some effort to provide financial restitution to the victim.

Finland and Germany’s efforts to control and reduce prison populations may serve as an example for the United States to reduce its incarcerated population. While these two nations differ from the United States along a variety of dimensions, they both demonstrate that policy changes can be effective at controlling and even reducing prison populations. Certain features of the United States, such as its common-law legal system, may make it more difficult to achieve the level of success that Finland has had in its history. However, it is unlikely that incarceration rates in the United States will drop to levels of other advanced Western democracies absent any changes to sentencing policies and practices.

Conclusion

The incarceration rate in the United States far surpasses that of any other advanced Western democracy. This disparity in incarceration can be attributed to differences along a variety of factors including sentencing policies and the common-law legal system used in the United States. While some factors may be difficult to control because they are foundational, e.g., common-law legal system, there is evidence that changing sentencing and corrections policies can have a considerable impact on incarceration rates.

Bibliography:

Blumstein A, Beck AJ (1999) Population growth in U.S. prisons, 1980–1996. Crime & Justice 26:17–61.
Blumstein A, Cohen J (1973) A theory of the stability of punishment. J Crim Law Criminol 64(2):198–207
Blumstein A, Tonry M, Van Ness A (2005) Cross-national measures of punitiveness. In: Tonry M, Farrington DP (eds) Crime and punishment in Western countries. University of Chicago Press, Chicago, pp 1980–1999
DeMichele M (2010) Three worlds of western punishment: a regime theory of cross-national incarceration rate variation, 1960–2002. Doctoral dissertation
Doob AN, Webster CM (2006) Countering punitiveness: understanding stability in Canada’s imprisonment rate. Law Soc Rev 40(2):325–368
Falck S, von Hofer H, Storgaard A (2003) Nordic criminal statistics, 1950–2000. Department of Criminology, Stockholm University, Stockholm
Farrington DP, Langan PA, Tonry M (2004) Crossnational studies in crime and justice. Bureau of Justice Statistics, Washington, DC
Graham J (1990) Decarceration in the Federal Republic of Germany: how practitioners are succeeding where policy-makers have failed. Br J Criminol 30(2):150–170
Guerino P, Harrison PM, Sabol WJ (2011) Prisoners in 2010. Bureau of Justice Statistics, Washington, DC
Heinz W (2006) Penal sanctions and sanctioning practice in the Federal Republic of Germany 1882–2004. The Konstanz repositories on crime and sanctioning. Retrieved 30 Oct 2009, from http://www.uni-konstanz.de/rtf/kis/sanks04_eng.htm
International Centre for Prison Studies (nd) World prisonbrief. Retrieved 10 Feb 2012, from http://www. prisonstudies.org/info/worldbrief/
Jacobs D, Helms R (1996) Towards a political model of incarceration: a time-series examination of multiple explanations for prison admission rates. Am J Sociol 102:323–357
Jacobs D, Kleban R (2003) Political institutions, minorities, and punishment: a pooled cross-national analysis of imprisonment rates. Soc Forces 82(2):725–755
Lappi-Seppala T (2001) Sentencing and punishment in Finland: the decline of the repressive ideal. In: Tonry M, Frase RS (eds) Sentencing and sanctions in western countries. Oxford University Press, Oxford
Lappi-Seppala T (2004) Penal policy and prison rates: Long-term experiences from Finland. The National Research Institute of Legal Policy, Helsinki.
Lappi-Seppala T (2007) Trust, welfare, and political economy: cross-comparative perspectives in penal severity. In: Traskman PO (ed) Rationality and emotion in European penal policy: Nordic perspectives. DJOF, Copenhagen
Lynch JP (1988) A comparison of prison use in England, Canada, West Germany, and the United States: a limited test of the punitive hypothesis. J Crim Law Criminol 79(1):180–217
Lynch JP (1993) A cross-national comparison of the length of custodial sentences for serious crimes. Justice Q 10(4):639–660
MacKenzie DL (2006) What works in corrections: reducing the criminal activities of offenders and delinquents. Cambridge University Press, Cambridge
MacKenzie DL, Weiss DB (2009) Other countries have successfully reduced incarceration rates without increasing crime: we can do it! Vict Offenders 4(4):1–7
Minton TD (2011) Jail inmates at midyear 2010 – statistical tables. Bureau of Justice Statistics, Washington, DC National Research Institute of Legal Policy (2011) Crime and criminal justice in Finland 2010. National Research Institute of Legal Policy, Helsinki
Neapolitan JL (2001) An examination of cross-national variation in punitiveness. Int J Offender Ther Comp Criminol 45(6):691–710
Ruddell R (2005) Social disruption, state priorities, and minority threat: a cross-national study of imprisonment. Punishm Soc 7(1):7–28
Sutton JR (2000) Imprisonment and social classification in five Anglo-American democracies. Am J Sociol 106:350–386
Sutton JR (2004) The political economy of imprisonment in affluent western democracies, 1960–1990. Am Sociol Rev 69(2):170–189
Tornudd P (1993) Fifteen years of decreasing prisoner rates. National Research Institute of Legal Policy, Helsinki
United Nations Office on Drugs and Crime (2011) 2011 Global study on homicide: trends, contexts, data. United Nations Office on Drugs and Crime, Vienna
Van Dijk JJM, van Kesteren JN, Smit P (2007) Criminal victimization in international perspective: key findings from the 2004–2005 ICVS and EU ICS. Boom Legal Publishers, The Hague
Walmsley R (2009) World prison population list. International Centre for Prison Studies, London
Weigend T (2001) Sentencing and punishment in Germany. In: Tonry M, Frase RS (eds) Sentencing and sanctions in western countries. Oxford University Press, Oxford
Weiss DB, MacKenzie DL (2010) A global perspective on incarceration: how an international focus can help the United States reconsider its incarceration rates. Vict Offenders 5(3):268–282
Young W, Brown M (1993) Cross-national comparisons of imprisonment. Crime Justice 17(1):1–49