She was the architect and instigator of contraceptive coverage by insurance.

But many states have passed their own laws, requiring at least some employers to provide contraceptive coverage.

Since the commission's ruling, the fight for contraceptive coverage has moved to college campuses, too.

Full equity in contraceptive coverage will likely continue to be fought for only at the court level, rather than being guaranteed by federal law.

Sticking points included education, census sampling and contraceptive coverage in Federal health plans.

But the matter of contraceptive coverage stood out as chief among them.

Some union insurance plans for workers at Catholic hospitals include contraceptive coverage.

"And it's disturbing, because millions of women throughout the country depend on contraceptive coverage through their health plans."

Most likely, though, the issue of contraceptive coverage will continue to be fought out in the courts.

Federal health plans will now be required to provide contraceptive coverage for Federal workers.