This view of morality has been criticized as gender-biased, most notably by Carol Gilligan. It places the highest value on universal moral principles, but these become clearest when they lead to conflict with society's established ethos. Consider two people, one whose self-justifying ends focus on fundamental human rights and personal freedom, and another who is at the same stage of development, but gives intrinsic value to relationships and community. The former is more likely to be a troublemaker, and thus stand out as someone who believes strongly in an independent morality. The latter will direct hir energy towards producing consensus and avoiding destructive kinds of conflict, which makes hir seem more conventional and socially conditioned.

You don't have to be a feminist to notice that most women tend to form larger, more complex social networks than most men, or that men make more frequent use of domination and social posturing. These tendencies suggest that women who are fully postconventional in their morality might still choose to obey an unjust law, choose a family over a career, or subordinate their own desires to others'. This is not because they're unable to think beyond social approval and societal reward and punishment -- it's because they value harmony highly enough to give up other concerns.

Another gender-based criticism of Kohlberg is that he views logical reasoning as being the mechanism for moral development -- one generalizes the rules one learns, from stage to stage, until reaching a point where the moral calculus can be completely pure, proceeding from the first principles of one's morality rather than from irrational feelings or social dogma. But the story of scholarly feminism in the last 40 years has largely been about the redemption of emotion as a legitimate tool of reason. That discussion is beyond the scope of this node, but suffice it to say that feelings about what is proper and what is an abomination help us hedge our bets against thinking we understand something we don't, and potentially overreaching ourselves. Women may be more likely to realize this, and discard reason as the ultimate tool of morality even though they're perfectly capable of using it instrumentally -- and may even use reason to justify this decision.

Overall, Kohlberg's model is useful insofar as it illuminates the journey most people make from unreflective selfishness to life as part of a culture to -- if they play their cards right -- enlightenment or self-actualization. However, measures of moral development that do not carefully consider the most distal reasoning behind a judgement threaten to overrate rebellious behavior and miss the virtues of care-oriented thinking.

For more on Gilligan Vs. Kohlberg, see http://www.stolaf.edu/people/huff/classes/handbook/Gilligan.html, or Gilligan's book In a Different Voice.