In Hawaii Housing Authority v. Midkiff, 467 U.S. 229 (1984), the Hawaii government sought to eliminate the land oligopoly that was skewing Hawaii's real estate market and inflating land prices. Midkiff, 467 U.S. at 231-32. In 1967, the Hawaii legislature passed the Land Reform Act which authorizes the government to use its power of eminent domain to condemn land held by the few. Id. In a unanimous opinion authored by Justice O'Connor, the United States Supreme Court held that a taking of a private property by the government in an effort to divide a land oligopoly was constitutional. Id. at 241-42. The Act permitted tenants to request governmental condemnations of their landlord's property and the option to purchase the property for a nominal fee. Id. at 233-34. Under the Act: Tenants . . . are entitled to ask the Hawaii Housing Authority (HHA) to condemn the property on which they live. When 25 eligible tenants, or tenants on half the lots in the tract, whichever is less, file appropriate applications, the Act authorizes HHA to hold a public hearing to determine whether acquisition by the State of all or part of the tract will "effectuate the public purposes" of the Act. If HHA finds that these public purposes will be served, it is authorized to designate some or all of the lots in the tract for acquisition. It then acquires, at prices set either by condemnation trial or by negotiation between lessors and lessees, the former fee owners' full "right, title, and interest" in the land. After compensation has been set, HHA may sell the land titles to tenants who have applied for fee simple ownership. Id. at 233-34.