One important impact of the Bhe v Magistrate Khayelitsha ruling was the creation of the Recognition of Customary Marriage Act. But researchers studying its impact in South Africa in March 2016 found: The implementation of the Recognition of Customary Marriage Act and of intestate succession rules found that in most cases, when a family member died, the estate was administered outside the new rules, and the families did not follow the new rules when distributing the estates.48 The continued administration of estates outside the civil law—and continued discrimination against women in inheritance rights—shows that legal change alone is not enough to change some harmful practices without addressing the root causes of such opportunism, including a lack of legal empowerment, unequal power dynamics between genders and within families, and a lack of enforcement of formal law. 48 Chuma Himonga and Elena Moore, “South Africa: Inheritance – Women are still cut out,” March 3, 2016, http://allafrica.com/stories/201603031229.html (accessed January 11, 2017). “YOU WILL GET NOTHING” 20