federal civil servants the right to have their jobs terminated "only for such cause as will promote the efficiency of the service." Second, in the mid 20th century, courts in New York developed a rule that corporate directors could only be dismissed for a "just cause", requiring reasons related to the director's conduct, competence, or some economic justification. Third, since 1987, Montana has enacted a "wrongful discharge" law, giving employees the right to damages if "discharge was not for good cause and the employee had completed the employer's probationary period of employment", with a standard probation set at 6 months work. However a right to reasons before termination has never been extended to ordinary employees outside Montana. By contrast, almost all other developed countries have legislation requiring just cause in termination. The standard in the International Labour Organization Termination of Employment Convention, 1982 requires a "valid reason" for termination of a worker contract based on "capacity or conduct" and prohibits reasons related to union membership, being a worker representative, or a protected characteristic (e.g. race, gender, etc.). It also requires reasonable notice, a fair procedure, and a severance allowance if the termination is for economic reasons. Some countries such as Germany also require that elected work councils have the power to veto or delay terminations, to neutralize the employer's potential conflicts of interest. Most countries treat job security as a fundamental right, as well as necessary to prevent irrational job losses, to reduce unemployment, and to promote innovation. An alternative view is that making it easier to fire people encourages employers to hire more people because they will not fear the costs of litigation, although the empirical credibility of this argument is doubted by a majority of scholars. Because most states have not yet enacted proposals for job security rights, the default rule is known as "at-will employment". For example, in 1872, the California Civil Code was written to say "employment having no specified term may be terminated at the will of either party", and even employment for a specified term could be terminated by the employer for a wilful breach, neglect of duty or the employee's incapacity. In the late 19th century, employment at will was popularized by academic writers as an inflexible legal presumption, and state courts began to adopt it, even though many had presumed that contract termination usually required notice and justifications. By the mid-20th century