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Drug use in the United States has been cited for the growth in American prisons over the past decade. Heroin, once considered a drug to be avoided and scorned, has had resurgence in use by middle-class youth and white-collar professionals due to the increased purity of the drug and the lack of need to use needles for ingestion. Naltrexone has been used as a method of helping heroin addicts to end their drug dependency, but such programs have limitations in their use and effectiveness. This paper is drawn from an evaluation of a drug treatment program in Wilmington, Delaware. The goal of this paper is to review the factors that lead to successful drug treatment and the limitations on the success of drug treatment that the judiciary should consider when sentencing drug addicts.