 In two cases after Washington, the Court pulled back from its broad principle that a defendant in a criminal proceeding has a "right to a defense". In United States v. Valenzuela-Bernal (1982), the Court held that an argument by the government that it had an interest in deporting illegal aliens (some witnesses in the case) outweighed the defendant's right to "eye witness testimony". Additionally, in Taylor v. Illinois (1988), the Court held that "countervailing public interests" could also outweigh the defendant's compulsory process rights.
