Criminal statutes, civil laws and criminal justice policies pertaining to rape in general, marital rape in particular, and domestic violence have all been altered. The problems discerned in the aftermath of reform are discussed as they preclude the full protection of violently victimized women. An example is provided of the contrast between California's marital rape law and Michigan's sexual assault law. Specifically noted is that a wife who is raped is not deemed raped in California if she was unconscious, drugged, or mentally handicapped at the time of the offense, while in Michigan these same factors define higher levels of sexual assault. Conclusions explore the need for further progress in this area.