Criminological throught has generally considered women who are incarcerated as in need of moral reform. With changes in society, however, women have become increasingly independent and have accordingly been dealt with more severely by the courts, if not treated equally by the prison system. The courts have also come to recognize the existence of sexual discrimination in society at large and to deal with it. Glover vs. Johnson was a lawsuit concerning inequality of treatment and access to rehabilitative programming brought by seven women in the Michigan correctional system. The court rejected the defendant's argument that programming for women was not cost-effective due to their relatively small numbers, and ruled that programs for men and women must be substantially equal pay; equal pay for comparable jobs; and suits under revenue sharing acts, Title IX, and Title VII of the Civil Rights Act. Notes, 50 case citations, and 15 references are given.