in employment rates is partially explained by increased participation in educational opportunities. These decreases can be attributed to increased costs for employers to remain in compliance with ADA provisions; rather than bearing increased costs, companies hire fewer workers with disabilities. While popular conception is that the ADA has created the opportunity for legal recourse for those with disabilities, less than 10% of ADA related cases find in favor of the plaintiff. Prior to 1960 David Neumark and Wendy Stock found evidence that sex discrimination/equal pay laws boosted the relative earnings of black and white females and conversely reduced the relative employment of both black women and white women. Exceptions Where anti-discrimination legislation is in force, exceptions are sometimes included in the laws, particularly affecting the military and religious organizations. Military In many nations with anti-discrimination legislation, women are excluded from holding certain positions in the military, such as serving in a frontline combat capacity or aboard submarines. The reason given varies; for example, the British Royal Navy cite the reason for not allowing women to serve aboard submarines as medical and related to the safety of an unborn fetus, rather than that of combat effectiveness. Religious organizations Some religious organizations are exempted from legislation. For example, in Britain the Church of England, in common with other religious institutions, has historically not allowed women to hold senior positions (bishoprics) despite sex discrimination in employment generally being illegal; the prohibition was confirmed by a vote by the Church synod in 2012. Selection of teachers and pupils in schools for general education but with a religious affiliation is often permitted by law to be restricted to those of the same religious affiliation even where religious discrimination is forbidden. See also List of anti-discrimination acts Labour law Discrimination (Employment and Occupation) Convention (ILO Convention No. 111) Anti-discrimination laws in Brazil Employment equity (Canada) Employment discrimination law in the United States Employment discrimination law in the United Kingdom History of women in the military LGBT rights by country or territory Public accommodations Reasonable accommodation References External links Handbook on European non-discrimination law, Fundamental Rights Agency, 2011