Carol Gilligan believed that Kohlberg’s theory was biased by an exclusively masculine viewpoint. She suggested that his emphasis on abstract thought and impersonal laws reflected a typically masculine bias to favor thought over emotion. Gilligan claimed that women are more likely to emphasize emotions and interpersonal relationships than men and, therefore, more likely to score at stage 3 (the first stage in conventional morality). This did not mean that women were less moral than men, only that they made moral judgments in different ways. In effect, women made moral choices “in a different voice”, which was the title of her 1982 book. While Gilligan’s critique raises important points about Kohlberg’s exclusive focus on intellect, she also has been criticized for oversimplifying the female style of moral reasoning. Other research has shown that women are no more likely to score at stage 3 than men. In general, both women and men take issues of justice and empathy into account when making moral decisions.