Best Steakhouse in NYC?

Given the competition, that's a title that shouldn't be claimed or assigned lightly. But N.Y. Times restaurant critic Frank Bruni is calling Minetta Tavern "the best steakhouse in the city." Excerpts from Bruni's review:

. . . it’s serving some of the most expertly aged, flavorful and exquisitely prepared prime beef in New York. This beef is showcased in one trailblazing burger and two titanic steaks, the côte de boeuf for two and a bone-in New York strip, that have for two months now been the incessant talk of insatiable carnivores, who can’t get enough of them.

. . . Although little of the rest of Minetta’s food rises all the way to the extraordinarily high level of the beef, much of it is terrific.

While the best porterhouse on the best night at Peter Luger can be an amazement, there’s no seafood there as fine as the tender, sweet lobster in a big, crisp salad at Minetta or as this restaurant’s trout meunière, buttery and bedecked with crab meat. And at Minetta the servers don’t bark at you.

Here is his full review.

I may have to find an excuse to dine there soon.

But I am perplexed by something. At the top of the NYT article, it shows Minetta Tavern getting three out of a possible four stars. How does Bruni justify calling Minetta the best steakhouse in NYC if it doesn't garner four stars?