to 2001 showed that the uses of the term "gender", were much rarer than uses of "sex", was often used as a grammatical category early in this period. By the end of this period, uses of "gender" outnumbered uses of "sex" in the social sciences, arts, and humanities. It was in the 1970s that feminist scholars adopted the term gender as way of distinguishing "socially constructed" aspects of male–female differences (gender) from "biologically determined" aspects (sex). In the last two decades of the 20th century, the use of gender in academia has increased greatly, outnumbering uses of sex in the social sciences. While the spread of the word in science publications can be attributed to the influence of feminism, its use as a synonym for sex is attributed to the failure to grasp the distinction made in feminist theory, and the distinction has sometimes become blurred with the theory itself; David Haig stated, "Among the reasons that working scientists have given me for choosing gender rather than sex in biological contexts are desires to signal sympathy with feminist goals, to use a more academic term, or to avoid the connotation of copulation." In legal cases alleging discrimination, a 2006 law review article by Meredith Render notes "as notions of gender and sexuality have evolved over the last few decades, legal theories concerning what it means to discriminate "because of sex" under Title VII have experienced a similar evolution". In a 1999 law review article proposing a legal definition of sex that "emphasizes gender self-identification," Julie Greenberg writes, "Most legislation utilizes the word "sex," yet courts, legislators, and administrative agencies often substitute the word "gender" for "sex" when they interpret these statutes." In J.E.B. v. Alabama ex rel. T.B., a 1994 United States Supreme Court case addressing "whether the Equal Protection Clause forbids intentional discrimination on the basis of gender", the majority opinion noted that with regard to gender, "It is necessary only to acknowledge that 'our Nation has had a long and unfortunate history of sex discrimination,' id., at 684, 93 S.Ct., at 1769, a history which warrants the heightened scrutiny we afford all gender-based classifications today", and stated "When state actors exercise peremptory challenges in reliance on gender stereotypes, they ratify and reinforce prejudicial views of the relative abilities of men and women." As a grammatical category The word was still widely used, however, in the specific sense of