A well-known maxim of all kinds of legal realism is that the identity of judges matters a great deal. The most famous account of this tenet is the apocryphal statement attributed to Jerome Frank declaring that what matters in the law is “what the judge ate for breakfast.” While Frank never put that in print, he did say that the “peculiar traits, disposition, biases and habits of the particular judge will, then, often determine what he decides to be the law;” in short, that “the personality of the judge is the pivotal factor in law administration.” A more epigrammatic and elegant summary of this position was given by none other than Carl Schmitt, who declared that “[w]hat matters for the reality of legal life is who decides.”