The Hawaiʻi Supreme Court, in an opinion issued Wednesday and authored by Associate Justice Todd Eddins, vacated Daniel R. Granillo’s 1990 Maui sexual-assault-related convictions after finding that now-discredited FBI hair-and-fiber testimony helped underpin the verdict.
In Granillo v. State (No. SCWC-22-0000740), the Hawaiʻi Supreme Court vacated Daniel R. Granillo’s decades-old convictions for kidnapping and sexual-assault-related charges stemming from a May 1989 attack, ordering a new trial.
The court concluded that Granillo’s trial was tainted by expert testimony from an FBI agent about microscopic hair comparison and fiber evidence—methods whose courtroom claims have since been substantially undermined. In the 1990 trial, FBI Special Agent Wayne Oakes testified that hair found in Granillo’s car belonged to the victim and that fibers from the victim’s clothing matched materials in Granillo’s car, according to reporting by Courthouse News Service.
Writing for the court, Eddins framed the ruling as a state constitutional due-process decision, emphasizing that the constitutional injury occurs when a conviction is obtained using materially false evidence—even if no one at the time knew the science would later be questioned. The opinion also rejected the lower court’s approach to treating the error as harmless, instead focusing on whether the false testimony could have affected the jury’s verdict.
Eddins’ decision included broader criticism of the U.S. Supreme Court’s modern constitutional direction and urged Hawaiʻi courts to interpret the state constitution independently, rather than treating federal doctrine as controlling in state constitutional cases.
Courthouse News Service reported that two members of the court agreed Granillo should receive a new trial but differed on the legal framework for evaluating the impact of the erroneous forensic testimony.
The ruling adds to a growing body of state-court decisions reassessing older convictions that relied on forensic techniques once presented to juries as highly reliable but later shown to be scientifically limited or overstated.
