In Europe, three models are emerging that deviate from the traditional system of largely unpaid prisoners' work: (1) Minimum Wage Model: Since 1993, in Austria, all working prisoners are legally entitled to 60 to 90 percent of the legally guaranteed gross income of an unskilled metal worker; (2) Deregulation Model: In some countries, e.g., France, Belgium, Greece, Italy, and Spain, prisoners who want to work are employed if work is available, but those who do not want to work are not compelled to work; and (3) Bifurcation Model: In Germany and some Scandinavian countries some prisoners are allowed to work outside prison with a normal contract, wages and fringe benefits, and some prisoners are granted intramural work leaves of absence. It should be noted, however, that the German federal constitutional court recently ruled that the present remuneration of prisoners in Germany violates the German constitution and charged the German parliament to amend relevant legislation by no later than the end of the year 2000. Notes, references