## Facts

- Ray Taylor was tried in Illinois state court for attempted murder and aggravated battery arising from a shooting.
- A pretrial discovery order required the defense to disclose its witnesses.
- After two prosecution witnesses testified, defense counsel sought to call Willie Dumas, a witness not previously disclosed.
- Defense counsel offered inconsistent explanations for the late disclosure, supporting the inference that the nondisclosure was tactical rather than inadvertent.
- The trial judge found a willful discovery violation and barred Dumas from testifying as a sanction.
- Taylor was convicted, and Illinois appellate courts affirmed the conviction and the sanction.

## Issues

1. Whether the Sixth Amendment Compulsory Process Clause (as applied to the States through the Fourteenth Amendment) prohibits a trial court from precluding a defense witness as a sanction for counsel’s willful violation of a discovery rule requiring disclosure of defense witnesses.

## Decision

- The Supreme Court affirmed the judgment, upholding Taylor’s conviction.
- The Court held that the Sixth Amendment does not categorically bar preclusion of a defense witness as a sanction for a willful and blatant discovery violation.
- The Court accepted the trial court’s finding that defense counsel’s nondisclosure was willful and aimed at securing an unfair advantage through surprise.
- The Court concluded that, given the circumstances and the state interests at stake, exclusion was not an arbitrary infringement of the right to present a defense.

## Legal Principles

- The Compulsory Process Clause protects a defendant’s ability to present witnesses but is not an unconditional right to introduce testimony free of reasonable procedural and evidentiary rules.
- A state may enforce discovery rules that reduce unfair surprise, support reliable factfinding, and ensure orderly trial administration.
- When a discovery violation is willful and tactical, a trial court may, in appropriate cases, preclude the undisclosed defense witness; lesser sanctions may be insufficient to cure prejudice and deter misconduct.
- Constitutional analysis is case-specific and may consider the willfulness of the violation, the potential prejudice and disruption, the materiality of the testimony, and the availability of alternative sanctions.
- The defendant may, in limited circumstances, bear the consequences of counsel’s willful misconduct when necessary to protect the integrity of the adversarial process.

## Conclusion

The Court held that a defendant’s Sixth Amendment right to compulsory process does not prevent a trial judge from excluding an undisclosed defense witness when the nondisclosure is willful and intended to gain unfair advantage, and when exclusion is justified to protect fairness and trial integrity.


Taylor v. Illinois, 484 U.S. 400 (1988)