A recent report from San Francisco noted that, while women and girls are the fastest growing segment of the juvenile justice population in that city, they are all but invisible in terms of programs and statistics. Apparently not much had changed since a 1992 survey of 154 service providers by the Delinquency Prevention Commission observed that the needs of young women in the juvenile justice system were "unexamined, untreated, and invalidated by both the system charged with serving them and by their own community and family support structures." The report further noted the lack of placement options for girls, the absence of community-based programs targeting the needs of girls or even collecting information on who the girls are, what they need, and what worked to meet their needs. In an attempt to determine the origins of this second-class treatment, the article briefly reviews: (1) the doctrine of the state as parent and how this notion was used to justify extreme governmental intervention in the lives of young people; (2) the Child-Saving Movement, the Juvenile Court and special attention to girls' moral behavior; (3) the deinstitutionalization movement; and (4) recent trends. The article includes recommended actions to meet the needs of girls who have entered the juvenile justice system. References, notes