ABSTRACT
An analysis of the Steel Seizure case illuminates how differently statesmen and craftsmen would decide a question involving the scope of governmental power. The Steel Seizure case also illustrates how Justices may mix styles of judicial decision making. For example, judicial statesmen frequently employ a craftsmanlike style. This case arose out of an attempt by the Hawaii legislature to redistribute land. A small number of persons owned most of the privately held land in Hawaii, and they chose to lease their property rather than sell it. The Supreme Court upheld the Hawaii statute in an opinion that echoed statesmanship concerns. The craftsman would admit that he has no authority to decide that question. However, the Constitution does not permit the legislature to use any means it wishes to achieve its policy goals, however desirable they may be.
