In 1982, Carol Gilligan published “In a Different Voice,” which became a famous critique of Kohlberg’s theory. Gilligan believed that Kohlberg’s theory was biased by an exclusively masculine viewpoint. She noted that the bulk of his subjects were male and that his emphasis on abstract thought and impersonal laws reflected his masculine bias. Gilligan claimed that women are more likely to emphasize empathy, interpersonal relationships, and concern for the feelings of others and are, therefore, more likely to score at level 3. This does not mean that women are less moral than men, only that they reasoned from a different set of values. While Gillligan’s critique raises important points about Kohlberg’s prioritizing intellect over emotion, she also has been criticized for over-simplifying the process of moral reasoning in women. Subsequent research has shown that women are no more likely to score at level 3 than men. In general, both women and men take issues of justice and empathy into account when making moral decisions.