The past decade has witnessed an interesting experiment in sentencing practices within the state of Florida. During the 1980's, the legislature adopted a number of sentencing reforms including the abolition of parole and indeterminate sentencing and the enactment of various mandatory minimum and Habitual Offender sentencing laws. The Habitual Offender laws state that a population of criminals in Florida are habitually involved in serious criminal activities and are responsible for the majority of crimes committed in Florida. They go on to state that incarcerating these criminals will reduce Florida's crime rate and that the costs of incarcerating those habitual offenders will be offset by savings to public in terms of reduced crime rates and victim losses. Studies conducted by the National Council on Crime and Delinquency conclude that it will be impossible for Florida to avoid either a massive crowding situation or an equally massive prison construction and expansion program, costing hundreds of millions of dollars that the state does not have, unless dramatic and substantial sentencing reforms are immediately adopted.