 In the US from the 1940s on, courts gradually began to enforce the Equal Protection clause of the 14th Amendment to apply strict scrutiny to state-imposed categorizations based on race; later on, constitutional law began to address whether race and sex could be analogized or even coupled for purposes of analysis (Mayeri 2011). In 1963, the US Congress passed the Equal Pay Act, amending the Fair Labor Standards Act to prohibit unequal pay on the basis of sex for “equal work on jobs the performance of which requires equal skill, effort, and responsibility, and which are performed under similar working conditions,” 29 U.S.C. §206(d) (2012). (Congress, in a dispute about comparable worth, left open the interpretive question of whether this statute requires the same pay for the same work or equal pay for substantially equivalent jobs, a comparable worth standard.) The Civil Rights Act of 1964 followed the next year, explicitly establishing rights not to be discriminated against on the basis of race, sex, religion or national origin in areas that included employment (Title VII), education (Title IX) and governmental benefits. Many nations have similar laws (phrased in varying language) and these have been or could be of considerable benefit to women, especially where bias is overt and provable.