Attempts have been made to combat discrimination against women (Wolfe, 1995). Congress passed the Equal Pay Act of 1963, and some government commissions were appointed to examine changes in the roles of women. Th e Women’s Educational Equity Act of 1974 allocated funding for counseling women. Th e 1975 passage of Title IX of the Educational Amendments Act sought to eliminate sexual discrimination in college admissions, fi nancial aid, physical facilities, curricula, sports, counseling, and employment in educational institutions receiving federal funds. However, the degree of real gain is questionable because of uneven enforcement and subsequent court decisions that restricted the impact of legislation. In the late 1970s, the Comprehensive Education Training Act began programs to retrain displaced homemakers, but the Reagan administration ended these limited programs in the early 1980s. During the same time, failure to ratify the Equal Rights Amendment contributed to further stagnation and erosion of women’s rights. More recently, the Fair Pay Act of 2009 aims to reduce wage disparities between women and men; however, discrimination in the workplace remains (Abney, 2011).