Judicial restraint is a judicial interpretation that recommends favoring the status quo in judicial activities; it is the opposite of judicial activism. Aspects of judicial restraint include the principle of stare decisis; a conservative approach to standing and a reluctance to grant certiorari; and a tendency to deliver narrowly tailored verdicts, avoiding "unnecessary resolution of broad questions."
That is because Engels presented things much worse than they actually were so as to prove a point and spread his ideology. Of course that a little bias was necessary for that since it had to motivate people that they had it worse than they really had it.