This may be due to their lesser access to legal services and to a correctional atmosphere that encourages dependency. In past litigation, inmates have been granted the ability to use the first, fourth, fifth, sixth, and eighth amendments to challenge prison policies concerned with freedom of communication, access to courts, visitation, religion, discipline, classification, parole, and search and seizure. Other litigation has dealt with due process issues, the right to counsel, and prison conditions. Most litigation concerning female inmates has involved the use of the equal protection clause, the eighth amendment prohibition against cruel and unusual punishment, and Section 1983 of the Civil Rights Act of 1871. Possible avenues for future litigation by female inmates include Title VII of the Civil Rights Act of 1964, which could be used to gain greater parity in employment and training opportunities, and the Equal Rights Amendment (if passed), which could provide a basis for remedying sex discrimination in prison conditions and program provision. While recent court decisions have resulted in some erosion of rights accorded inmates, there will be new challenges that will keep the prisoners' rights movement alive. Women should receive their fair share of benefits from such litigation. 18 notes and 24 references.