Another possibility is that people that don't return the cart may not be having their needs met. A person who is tired after walking across the hot parking lot may not return it out of a desire to maintain a modicum of health. Or, perhaps, they may not think about it because their cognition is temporarily hindered by hunger, exhaustion, or some other carnal need.
On Maslow's hierarchy, I'd say if a person meets all of their physiological and safety needs they are more likely to return the cart than those who do not.
If they're so tired after walking around the shop and walking back to their car that they can't do that tiny bit more and return the cart to the corral, maybe they should be seeing a doctor to see if they are eligible for disability (sounds like a severe case of lazybonesitis) and use a handicapped spot. Or you know, stop being so fucking lazy and making excuses.