In her book In a Different Voice Gilligan presented her ethics of care theory as an alternative to Lawrence Kohlberg's hierarchal and principled approach to ethics. In contrast to Kohlberg, who claimed that girls, and therefore also women, did not in general develop their moral abilities to the highest levels, Gilligan argued that women approached ethical problems differently from men. According to Gilligan, women's moral viewpoints center around the understanding of responsibilities and relationship whilst men's moral viewpoints instead center around the understanding of moral fairness, which is tied to rights and rules. Women also tend to see moral issues as a problem of conflicting responsibilities rather than competing rights. So whilst women perceive the situation as more contextual and narrative, men define the situation as more formal and abstract. In her 2011 article about In a Different Voice, Gilligan says she has made "a distinction [she] ha[s] come to see as pivotal to understanding care ethics. Within a patriarchal framework, care is a feminine ethic. Within a democratic framework, care is a human ethic. A feminist ethic of care is a different voice within a patriarchal culture because it joins reason with emotion, mind with body, self with relationships, men with women, resisting the divisions that maintain a patriarchal order". She calls the different moral approaches "ethics of care" and "ethics of justice" and recognizes them as fundamentally incompatible.