In the Garnes case, women were paroled later than men with similar sentences and circumstances. In the Costello and Chambers cases, women received longer sentences than men with similar criminal experiences and convictions. In all instances women sought relief first from the courts and then from the legislature. While an end to discriminatory treatment as sought by the plaintiffs was ordered by courts in Washington, D.C. and in New Jersey, the impact was significantly different. In Garnes, a settlement became effective on December 10, 1976, stipulating that D.C. women would remain in Federal prisons but would return to D.C. Department of Corrections' jurisdiction at least 9 months before their parole eligibility date. However, it was not discovered until 1981 that the agreements made in the case were not being carried out. Further, action was not taken to correct this failure until 1982. Unlike the Garnes case, the Costello and Chambers cases produced the intended reform, a gender neutral sentencing code that went into effect in September 1979. These studies reveal that legally mandated change is just a paper victory without effective implementation. Finally, they suggest that court orders and statutes may be just the beginning of women's struggles to change the condition of their lives. Included are 33 notes.