On January 18, 1989, the Supreme Court upheld federal sentencing guidelines which removed rehabilitation from serious consideration when sentencing offenders. The Court outlined the history of the debate: “Rehabilitation as a sound penological theory came to be questioned and, in any event, was regarded by some as an unattainable goal for most cases.” The Court cited a Senate Report which, “referred to the ‘outmoded rehabilitation model’ for federal criminal sentencing, and recognized that the efforts of the criminal justice system to achieve rehabilitation of offenders had failed.”
Robert Magnus Martinson (May 19, 1927 – August 11, 1979) was an American sociologist, whose 1974 study "What Works?", concerning the shortcomings of existing prisoner rehabilitation programs, was highly influential, creating what became known as the " nothing works " doctrine.  His later studies were more optimistic, but less influential at the time.  He served as chairman of the Sociology Department at the City College of New York , and then founded the Center for Knowledge in Criminal Justice Planning.