Taylor v. Illinois
Citation and Court
484 U.S. 400 (1988), Supreme Court of the United States
Facts
During trial for attempted murder, the defense sought to call a previously undisclosed witness whose name had not been provided to the prosecution in violation of the state’s reciprocal discovery rules. The trial court, finding the discovery violation was willful, excluded the witness. The defendant argued this infringed his Sixth Amendment right to compulsory process.
Issue
Whether excluding a defense witness as a sanction for a willful discovery violation violates the Sixth Amendment right to compulsory process.
Holding
The Sixth Amendment right to compulsory process is not absolute; a trial court may exclude a defense witness as a sanction for a deliberate and willful discovery violation when the other party would be prejudiced and less severe remedies would be inadequate.
Rule / Doctrine
The compulsory process clause guarantees defendants the right to present witnesses, but that right is subject to evidentiary and procedural rules of general applicability. When a defendant willfully violates discovery rules, the trial court may impose exclusion as a sanction if the violation was deliberate and the prosecution would suffer prejudice from the late disclosure.
Significance
Taylor confirms that the Sixth Amendment right to present a defense is not unlimited and can yield to legitimate procedural rules. It establishes that courts may sanction discovery abuse by excluding evidence or witnesses, balancing the defendant’s right against the integrity of the adversarial process.