Since the 1960s, much has been done to improve the status of victims in the criminal justice system, as well as to meet victims� financial and other tangible needs caused by crime. The author explores the inherent difficulties in implementing any kind of full or consistent restorative justice model within our present criminal justice system. She reviews how restorative justice has been reflected in the criminal justice system, opposition to restorative justice, and the programmatic changes that would have to occur to realize restorative justice.