Many politicians, business leaders, and scholars discount the role of public policy and emphasize the role of the labor market when explaining employers' maternity-leave policies, arguing that prior to the passage of the Family and Medical Leave Act (FMLA) of 1993, employers were already providing maternity leave in response to the increase in the number of women workers. Employers did create maternity-leave programs in the 1970's and 1980's, but not as a purely voluntary response in the absence of any government mandate. In 1972, the Equal Employment Opportunity Commission (EEOC) ruled that employers who allowed leaves for disabling medical conditions must also allow them for maternity and that failure to do so would constitute sex discrimination under the Civil Rights Act of 1964. As early as 1973, a survey found that 58 percent of large employers had responded with new maternity-leave policies. Because the 1972 EEOC ruling was contested in court, the ruling won press attention that popularized maternity-leave policies. Yet perhaps because the Supreme Court later struck down the ruling, politicians and scholars have failed to recognize its effects, assuming that employers adopted maternity-leave policies in response to the growing feminization of the workforce.