The discussion notes that most States' parole laws do not create a liberty interest in parole providing full due-process protections; therefore, battered women inmates must rely on their equal protection rights for redress. However, current methods for the use of protest letters in some States violate the Constitution's equal protection clause. States that provide no investigation of the contents of protest letters in any form and do not allow the inmate any access to such letters for inmate investigation and rebuttal violate the constitutional rights of battered women inmates, even in cases in which State laws do not create a liberty interest in parole. However, many protest letters submitted in parole hearings are often unreliable or based on hearsay. In addition, they often have little or nothing to do with the factors that State parole boards are required to consider. Incarcerated battered women may be affected by both the traditional protest letters and letters sent by the deceased batterers' family, who often deny that abuse occurred, and by trial officials, who undervalued or rejected the self-defense claim at trial. Therefore, States should not use protest letters until appropriate procedures are in place that protect an inmate's equal protection rights and the integrity of the parole process. For many incarcerated battered women, parole may be the last resource in a justice system that failed to recognize the legitimacy of their defense. Footnotes (Author abstract modified)