From the introduction:
Social expectations that girls behave obediently, modestly, and cautiously have been remarkably durable over more than one hundred years of juvenile justice in the United States, and throughout that time these expectations have masked structural gender discrimination. At the turn of the twentieth century, these expectations were behind the proliferation of training schools for immigrant girls who were perceived to be immoral and in need of guidance that would enable them to marry and to become responsible mothers. In the mid– and late twentieth century, these expectations supported detention and incarceration of girls for status offenses, for technical probation violations, and particularly for running away. Now, these same expectations result in the detention and incarceration of girls who fight back at home or in intimate relationships and who are victims of sexual exploitation.
Francine Sherman. "Justice for Girls: Are We Making Progress?." UCLA Law Review 59, no.6 (2012): 1584-1628.