How Justice Eddins Built a Blueprint Against Originalism

Granillo v. Hawaii made Justice Todd Eddins harder to dismiss as a writer of vivid concurrences and easier to read as something more consequential: a state constitutional architect. The July 2026 opinion drew attention for the phrase “white sight,” which Slate described as part of “the most sweeping indictment yet” of the Roberts Court’s constitutional project, reaching across voting rights, due process, campaign finance, and the Second Amendment.[1] The phrase will travel because it is sharp. The legal question is whether it travels alone.

It does not. By the time Granillo arrived, Eddins had already been building a set of moves that recur with enough regularity to matter: state constitutional primacy, refusal to lockstep Hawaii law to federal minimums, use of the Aloha Spirit statute as interpretive material, and a methodological attack on originalist history as both selective and administratively dangerous. For readers who want that methodology separated from the case sequence, the companion analysis of Eddins’ “white noise” approach to state constitutional doctrine is the static map. The record from Sunoco to Granillo shows how the map was drawn.

One caution belongs near the front. The original Hawaii Supreme Court PDFs for these opinions were not directly verified for this article. The quotations attributed to Eddins here come through secondary legal and news sources that reproduced them, including Slate, Gravier House, Bolts, State Court Report, Americans United, Courthouse News, and Federalist Society commentary. That does not make the quotes unusable; it does mean the citation trail should be read with the same care lawyers bring to any reproduced judicial language.

Granillo changed the scale of the story

Before Granillo, Eddins could be read as a justice who had strong views about Bruen, police interrogation, church-state separation, climate accountability, and the limits of federal constitutional fashion. After Granillo, those subjects look less like separate provocations and more like applications of a general theory. The point is not that every issue becomes the same issue. It is that each issue becomes an occasion to ask the same prior question: why should Hawaii treat the Roberts Court’s historical method as the ceiling of constitutional meaning?

The “white sight” language matters because it names a perceived defect in originalist authority, not merely a policy disagreement with conservative outcomes. As reported by Slate, Granillo framed the Court’s method as a system that privileges some histories, some legal actors, and some constitutional harms while rendering others peripheral.[1] Courthouse News likewise treated the decision as nationally significant, not simply as an island-state eccentricity.[2] That is the point at which the opinion becomes useful to litigators: it converts critique into vocabulary that can be deployed in briefs about whose history counts, what level of generality controls, and whether state courts must accept federally curated memory as constitutional command.

Still, Granillo is not best understood as the beginning. It is the capstone. Its force depends on the opinions that came before it, especially because Eddins did not reserve his objections for one doctrinal battlefield. He moved from climate jurisdiction to guns, from custodial interrogation to establishment concerns, then back to a broader indictment of federal constitutional method. That sequence is what gives the criticism its legal weight.

Sunoco: the opening posture

The first major move came in October 2023, in the Sunoco climate litigation. Eddins’ concurrence, as reproduced and discussed by Gravier House, rejected personal-jurisdiction challenges while signaling that Hawaii need not “take instruction” from federal due process doctrine as filtered through the U.S. Supreme Court’s originalist turn.[3] The language was already combative. He referred to “hubristic originalists” and criticized Citizens United, not as an isolated campaign-finance mistake, but as evidence of a Court willing to constitutionalize a narrow political economy under the cover of method.[3]

Sunoco did not yet contain the full toolkit. It supplied the posture. A state court, in Eddins’ account, is not an inferior federal court with local scenery. It has its own constitution, its own statutory commitments, and its own interpretive responsibilities. The Aloha Spirit, codified in Hawaii law, entered not as decorative cultural language but as a guide to public values that a Hawaii court may consider when reading Hawaii law.[3]

That move is easy to caricature and harder to answer. If the Aloha Spirit is treated as sentiment, it sounds soft. If it is treated as enacted law, the analysis changes. The interpretive question becomes whether a state court may use a state statutory expression of public philosophy to resist importing federal doctrine that is only a constitutional floor. Eddins’ later gun opinions would make that question unavoidable.

Wilson: the Bruen collision

State v. Wilson, decided in February 2024, brought the first full public collision with the Roberts Court’s originalist doctrine. The Hawaii Supreme Court unanimously repudiated Bruen’s application to Hawaii’s firearm regime, with the quoted line that “the spirit of Aloha clashes with a federally mandated lifestyle that lets citizens walk around with deadly weapons.”[4] The opinion also used the Wire-inflected line, “The thing about the old days, they the old days,” as reported in coverage of the case.[5]

The line was memorable, but Wilson’s more important contribution was structural. Bruen had instructed courts to decide Second Amendment disputes through historical analogy. Eddins treated that instruction as especially ill-suited for a state whose legal traditions, public-safety conditions, and constitutional identity do not map cleanly onto mainland founding-era materials. In Wilson, anti-lockstepping stopped being an abstract state constitutional preference and became a litigation position: Hawaii could read its own constitution, and its own public-law commitments, without surrendering the field to a federal history test.

This is where conservative criticism becomes legally useful. Federalist Society analysis treated Wilson not as harmless rhetoric, but as a direct challenge to Bruen’s supremacy in practical litigation.[6] That reaction clarifies the stakes. Originalist lawyers did not object merely because Eddins was rude to the U.S. Supreme Court. They objected because Wilson suggested a route by which state courts could preserve local regulatory judgments by emphasizing independent state constitutional grounds and state-specific interpretive materials.

Wilson also shows the limits of the route. The U.S. Supreme Court later reversed in Wolford v. Lopez in June 2026, a fact that prevents any serious account from presenting Eddins’ approach as immunity from federal review.[6] The better reading is narrower and more useful: Wilson forced the conflict into the open, gave litigants a model for framing state constitutional resistance, and then exposed where federal supremacy can still cut through. For a closer treatment of that sequence, see Hawaii Rejected Bruen with the Aloha Spirit — Then SCOTUS Reversed.

The useful residue after Wolford is not the claim that Hawaii can ignore Bruen. It is the more modest and more durable claim that state courts can decide, issue by issue, whether federal doctrine answers the state constitutional question at all. On guns, that inquiry now sits under tighter federal pressure. On other subjects, the same architecture may have more room to operate. The statutory and constitutional background of that argument is developed further in Aloha Spirit and the Second Amendment After Bruen.

Zuffante: adaptation without theatrics

The September 2025 interrogation-recording ruling in Zuffante is less famous than Wilson and less explosive than Granillo. It may be more revealing for that reason. As Bolts reported, Eddins wrote that “a constitution adapts” in mandating custodial-interrogation recording under the Hawaii Constitution.[7] The case concerned police questioning, not guns or campaign finance. The move was still recognizably part of the same project.

A recording rule is a practical remedy. It changes what police must do, what trial courts can review, what defense lawyers can test, and what appellate courts have before them. In that setting, “a constitution adapts” is not merely a theory of living constitutionalism. It is a justification for updating procedural safeguards when old assumptions about proof no longer do the work.

Zuffante therefore supplies a middle piece in the blueprint. State constitutional interpretation is not only a shield against federal originalism; it can also generate affirmative procedural obligations. For practitioners focused on interrogation doctrine, the operational details belong in the separate profile on the Hawaii Supreme Court ruling on police interrogation recording. Here, its importance is that Eddins applied adaptive state constitutional reasoning in a criminal-procedure context where the remedy was concrete.

The church-state concurrence widened the field

Also in September 2025, Eddins wrote separately in an Establishment Clause context. Americans United reported his criticism that the “Roberts Court casually dismisses…the wall separating church and state,” again invoking the Aloha Spirit in constitutional analysis.[8] The phrasing put him in direct conversation with another major front in the Roberts Court’s jurisprudence: the weakening of strict separationist understandings of the First Amendment.

The concurrence matters because it prevents an overly narrow reading of Eddins as a Second Amendment outlier. By 2025, his opinions had touched climate accountability, firearm regulation, custodial interrogation, and church-state separation. The common feature was not subject matter. It was a refusal to let federal constitutional retrenchment define the full scope of state constitutional obligation.

This is also where the Aloha Spirit framework becomes more than a local flourish. Used once, it can be dismissed as atmospheric. Used across contexts, it becomes a state-law marker: a way of saying that Hawaii’s courts may consult Hawaii’s enacted commitments when federal doctrine moves in a different direction. Whether that move persuades outside Hawaii is a separate question. Within the blueprint, its function is clear.

Granillo as synthesis, not spectacle

Granillo’s breadth is what makes it different. Sunoco had announced posture. Wilson had confronted Bruen. Zuffante had turned adaptation into remedy. The Establishment Clause concurrence had widened the field. Granillo gathered the strands and aimed them at the larger legitimacy claim behind modern originalism.

As described in Slate’s July 2026 coverage, Eddins’ opinion did not limit itself to one doctrinal complaint. It connected voting rights, due process, campaign finance, and the Second Amendment in a broader critique of a constitutional system that, in his account, mistakes selective historical authority for neutral law.[1] That is why “white sight” is more than a headline phrase. It attempts to describe a mode of judicial perception: what the method sees easily, what it strains to see, and what it has been trained not to see.

For lawyers, the more important question is how much of that critique can be cited without asking a court to adopt the entire indictment. Some parts are readily portable: anti-lockstepping, state constitutional primacy, remedial adaptation, and skepticism toward historically selective analogies. Other parts are more volatile. The “white sight” formulation may sharpen a brief in the right case, but it may also give an opposing party an easy way to recast the argument as accusation rather than doctrine.

That distinction matters because Eddins’ opinions are not equally useful in every forum. A state supreme court with a tradition of independent constitutional interpretation may find the architecture familiar even if it avoids the rhetoric. A trial judge bound tightly by federal doctrine may find the same language unusable. A litigator challenging an originalist test may cite Granillo for its methodological critique while relying on Wilson or Zuffante for the more conventional state-law move.

Why the national reaction came after the doctrine

The national coverage is real. Eddins has drawn attention from Slate, Newsweek, Bolts, Americans United, the Federalist Society, National Review, Fox News, Courthouse News, and State Court Report.[1][2][4][6][7][8] But the coverage is a consequence, not the explanation. The opinions matter because they give both admirers and critics something to work with.

For progressive state constitutional lawyers, the attraction is obvious: Eddins supplies a language for refusing federal constitutional minimalism without pretending federal law is irrelevant. For originalist critics, the threat is equally obvious: if state courts can pair independent state grounds with a methodological critique of federal history tests, then Roberts Court victories may have less practical reach in some state-law settings than their national rhetoric suggests.

Neither side should overstate the result. Wilson’s reversal in Wolford shows that federal doctrine still has teeth when the U.S. Supreme Court has jurisdiction and chooses to use it.[6] State constitutional primacy is powerful where the state ground is independent and adequate. It is less powerful when a federal right supplies the controlling rule or when the state court’s reasoning cannot be separated from federal defiance.

The usable playbook in Q3 2026

By Q3 2026, Eddins has not defeated federal originalism. He has made visible a state-level playbook that can be studied, borrowed, narrowed, attacked, or contained. Its first move is jurisdictional humility in reverse: a state court recognizes federal supremacy where it must, but refuses to treat federal constitutional minima as the measure of all constitutional judgment. Its second move is anti-lockstepping: the state constitution is interpreted on its own terms. Its third move is local legal material: in Hawaii, that includes the Aloha Spirit statute. Its fourth move is methodological critique: originalist history is examined as a contested selection process, not accepted as neutral excavation.

The vulnerabilities are just as important. A state court that leans too hard on denunciation may make its reasoning easier to caricature. A state-law holding that is insufficiently independent may invite federal correction. A culturally specific framework like the Aloha Spirit may be persuasive in Hawaii precisely because it is Hawaii law, and less portable elsewhere unless another state has comparable constitutional or statutory material. The method is replicable; the sources are not interchangeable.

That is the practical implication for lawyers watching Eddins after Granillo. The opinions are not a permission slip to ignore the Roberts Court. They are a set of working instruments: identify the independent state ground, articulate why federal doctrine is a floor rather than a ceiling, anchor the analysis in state legal materials, ask what remedy follows, and decide how much methodological criticism the forum can bear. In some courts, the rhetoric will be the point. In others, the blueprint will work better if the loudest language is left on the cutting-room floor.

References

1. One Judge’s Supreme Court Horror Show, Slate, July 2026
2. Granillo v. Hawaii coverage, Courthouse News
3. Sunoco climate concurrence coverage, Gravier House, November 6, 2023
4. State v. Wilson coverage, State Court Report, February 2024
5. Amicus interview on State v. Wilson, Slate, May 2024
6. Federalist Society analysis of State v. Wilson and Bruen, Federalist Society
7. Hawaii Supreme Court police interrogations coverage, Bolts, September 2025
8. Establishment Clause concurrence coverage, Americans United, September 2025