The term is often attributed to "Ladies Love Outlaws", a song by Lee Clayton and sung by Waylon Jennings on the 1972 album of the same name. Another plausible explanation is the use of the term a year later by publicist Hazel Smith of Glaser Studios to describe the music of Jennings and Tompall Glaser. Art critic Dave Hickey, who wrote a 1974 profile in "Country Music" magazine, also used the term to describe artists who opposed the commercial control of the Nashville recording industry.