Bearden v. Georgia draws the line between someone who will not pay and someone who cannot. Revoking probation for the second, without inquiry, is unconstitutional.
What the court must actually do
Inquire into the reasons for nonpayment. Determine whether the defendant made bona fide efforts to pay. Consider alternatives to imprisonment where the failure was not willful. Skipping the inquiry is itself the error.
Where restitution calculations go wrong
Restitution is meant to make a victim whole, not to be collected twice. Where an insurance claim covered the same loss, the calculation should reflect it — and where it does not, the underlying worksheet and claim payment history are the records that show it.
The documented example
This record documents restitution assessed on a loss carrying an active insurance claim, with no reconciliation appearing in the file, alongside an indigency posture. See the ledger and the Bearden standard.