Why are there different methods of constructing the outer measure leading up to Lebesgue measure (open covering or closed covering?)?

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In studying outer measure (to build up to Lebesgue measure) I notice some authors construct the outer measure of $E$ as the infimum of the length/size of closed sets that cover $E$ (Royden) and sometimes as the infimum of the length/size of open sets that cover $E$ (Stein). Why the difference? Is one preferable over the other?

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To add even more complication, Folland constructs Lebesgue measure with right-closed half-open intervals.

The distinction is irrelevant, as ultimately we want that the Lebesgue outer measure restricted to the Borel $\sigma$-algebra is the Lebesgue measure (and in fact, when restricted to an algebra of Borel sets, is the premeasure induced by the function $F(x) = x$ on that algebra).

Since the Borel sets in $\mathbb{R}$ can be generated by open sets, closed sets, left-closed h-intervals, or right-closed h-intervals, it really matters not what we choose.