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The Supreme Court broadly interpreted the public use doctrine to mean that land seized under the takings clause of the Fifth Amendment of the U.S. Constitution must be used for the public interest or in some way serve a legitimate public purpose. The Court typically defers to the legislative branch in defining the extent to which a “public purpose” is achieved. For example, in Berman v. Parker (1954), a unanimous Court stated that the judiciary’s role in determining whether the government’s power to take lands and convert them to public use was being exercised for a public purpose was “extremely narrow.” Moreover, in Hawaii Housing Authority v. Midkiff (1984), the Court sustained Hawaii’s Land Reform Act of 1967, which sought to break up large estates and give families the ability to buy property from the state. Writing for the Court, Justice Sandra Day O’Connor argued that when “the legislature’s purpose is legitimate and its means are not irrational, our cases make clear that empirical debates over the wisdom of takings [are] not to be carried out in federal courts.”