page_title: Taylor v. Illinois
section_title: Opinion of the Court
hierarchical_section_title: Taylor v. Illinois / Opinion of the Court
caption_attribution_description: John Paul Stevens, U.S. Supreme Court justice.
context_page_description: Taylor v. Illinois, 484 U.S. 400, is a United States Supreme Court decision in which the Court held that defense witnesses can be prevented from testifying under certain circumstances, even if that hurts the defense's case. Taylor was the first case to hold that there is no absolute bar to blocking the testimony of a surprise witness, even if that is an essential witness for the defendant, a limitation of the broad right to present a defense recognized in Washington v. Texas.
  Taylor was the first Compulsory Process Clause case since Washington v. Texas to provide a specific limitation on the right of defendants to force their witnesses to testify. In that case, the Court construed a defendant's right very broadly in his ability to present a defense. Here, however, the Court restricted that ability to comply with court rules, especially if those rules were of equal consequence upon both the prosecution and the defense. This decision was reached over the dissent of three Justices, all of whom felt a defendant's case should not be limited based on an error solely by the defendant's attorney to list appropriate witnesses.
context_section_description: Justice John Paul Stevens wrote the opinion, which affirmed the decision of the Illinois Appellate Court, and upheld Taylor's conviction. He began by addressing the position of the state of Illinois, who argued that there is never a Compulsory Process Clause concern when preclusion of a witness is used as a discovery sanction. The Court had held the converse view, Stevens wrote that "few rights are more fundamental than that of an accused to present witnesses in his own defense". This strong footing of Sixth Amendment values forced the Court to reject the State's absolutist argument.
  At the same time though, the Court rejected the defendant's broad claim that there could never be preclusion of a defense witness. Stevens wrote that "[t]he Compulsory Process Clause provides [the defendant] with an effective weapon, but it is a weapon that cannot be used irresponsibly". The whole adversarial process would be destroyed, Stevens argued, if either side could simply refuse to follow the basic rules of the Court. There are "countervailing public interests" which weigh against the absolute defense position.
  The broader idea embedded in the opinion was the idea that willful misconduct of an attorney lowers the truthfulness of proffered testimony. In the instant case, the Court held that a trial judge could hold the "presumption" that a new witnesses' testimony is perjured due to "a pattern of discovery violations". The pattern in Taylor's case was a series of two amendments to the witness list done in bad faith. "It would demean the high purpose of the [Clause] to construe it as encompassing an absolute right to an automatic continuance or mistrial", Stevens wrote.
  As the misconduct of the judge towards the defense counsel did not implicate the Sixth Amendment's Compulsory Process Clause, there was no need to disrupt the lower courts' decisions. Further, even though the defendant was harmed by the defense counsel error, Stevens wrote that such an argument could not excuse the counsel's fault. 
  Despite the rejection of Taylor's constitutional position, the Court did create the framework for a balancing test for lower courts to use in handling future discovery preclusion questions. A trial court must balance the defendant's interest in a robust defense with the (i) state's interest in 'efficient' justice, (ii) state's interest in excluding evidence lacking integrity, (iii) state's interest in a strong judicial authority with followed rules, and (iv) the prosecution interest in avoiding prejudice due to a defendant's discovery violation.
caption: Justice John Paul Stevens wrote the majority opinion in Taylor v. Illinois.
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