David Carr (2002) has argued against the use of developmental theories as a basis for curriculum development in moral education. Although we find common ground with some aspects of Carr's arguments, we disagree with several of his criticisms of the cognitive-developmental approach to moral education. He confuses romantic ideology (as espoused by Rousseau and others) and progressive ideology (as espoused by Dewey and others); he assumes that developmental theories have no endpoint or final goal from which to structure moral education; and he argues against the use of psychological inquiry to validate a philosophical ought. This paper is an attempt to clarify Carr's arguments and propose a justification for the developmental approach to moral education.