Gilligan charges that Kohlberg’s downgrading of female moral sensitivity was just another case in a long history of male intellectual bias. Freud claimed that "women show less sense of justice than men.. . , that they are often more influenced in their judgments by feelings of affection or hostility."‘* He called women’s relationships the "dark continent" of psychology. Swiss child psychologist Jean Piaget wrote that "the most superficial observation is sufficient to show that in the main, the legal sense is far less developed in little girls than in boys? (Piaget ,1965, p. 77