The Hawaii Supreme Court issued a ruling on Wednesday in Granillo v. State of Hawaii that has drawn national attention for both its legal reasoning and its commentary on federal jurisprudence.
In May 1989, Daniel R. Granillo was accused of abducting a woman from a Maui shopping center parking lot, holding a knife to her neck, driving her to the Kahului breakwater, and sexually assaulting her. She escaped from a moving vehicle and sought help.
Granillo was convicted in July 1990 on kidnapping, two counts of first-degree sexual assault, and attempted first-degree sexual assault, receiving a 40-year sentence. The prosecution relied on the victim's testimony and microscopic hair and fiber analysis presented by an FBI expert.
The expert testified that a hair found in Granillo's car was consistent with originating from the victim and had been forcibly removed, and that fibers from her clothing matched materials in his vehicle. Courts had long accepted such analysis as reliable.
In 2017, state prosecutors were notified that the FBI had reviewed older cases and found the expert's testimony overstated the science. National research reports had concluded that microscopic hair and fiber analysis can provide only class-level associations, not individual identification.
Granillo filed a post-conviction petition. The state court expanded a "false evidence" rule under the state constitution's due process clause, held that prosecutorial knowledge of falsity was not required, and found a reasonable possibility the testimony affected the verdict. It ordered a new trial.
The 91-page opinion stated that Hawaii interprets its constitution independently of federal precedent. It characterized rulings of the U.S. Supreme Court as having no binding effect on state constitutional analysis.
The opinion criticized decisions on voting rights, campaign finance, and equal protection, arguing that federal jurisprudence had weakened democratic safeguards and civil rights remedies. It described such rulings as "white noise" for purposes of state constitutional interpretation.
The court asserted that state constitutions serve as a check when federal courts depart from protecting individual liberties. The decision has intensified debate over the limits of state judicial independence.
