In ancient history, in the East and the West, the inability to pay in full any debt incurred often resulted in the debtor becoming literally enslaved to the creditor. Julius Caesar is often credited (no pun intended) with the first major bankruptcy reform. His reform, deemed scandalous at the time, was that the debtor would remain free, however, the debtor would relinquish all of his property and 2/3 of all wages until the debt was paid in full. Debtors’ prisons did, however, make a return in the ancient common law and continued into the early 19th century. The U.S. Constitution made bankruptcy a federal civil (not criminal) issue and eventually abolished debtors’ prisons. The common law said the failure to repay a debt constituted theft. Modern law states that it is only theft if the unpaid debt was undertaken fraudulently or unpaid willfully. Should willful unpaid debt be considered a criminal or civil matter? How should debt through fraud be considered by the courts?