[citation][nom]ctbaars[/nom]I would think Steve Jobs would be a "public figure". And as such, is open to this kind of stuff. You cannot do it to a "private person".[/citation]Especially since it's not particularly insulting.
Now if it came with accessories like, say, half-eaten baby corpses, a pentagram base, or other such depravity, then sure, Steve himself could sue for libel. This one was made by fans for fans, so there's no room to whine about defamation.
If they removed all traces of Jobs' name and the Apple trademark from the figure, changed the likeness ever so slightly, and sell it as "The Magical Innovator" or something non-specific like that, they could probably get away with it. Small toy companies do that all the time- most Hollywood and many Chinese and Japanese action movie stars have an unofficial likeness out there.
The main issue really is the use of Apple and Jobs' names to sell this figure, both explicitly (by naming the sculpture) and tacitly (by selling it in a store that specializes in Apple gear). Outside of those things, Apple has no case.