holding that if the failure to disclose a defense witness was "willful and motivated by a desire to obtain a tactical advantage that would minimize the effectiveness of cross-examination and the ability to adduce rebuttal evidence, it would be entirely consistent with the purposes of the Compulsory Process Clause simply to exclude the witness's testimony"
How later courts described this case
- holding that if the failure to disclose a defense witness was "willful and motivated by a desire to obtain a tactical advantage that would minimize the effectiveness of cross-examination and the ability to adduce rebuttal evidence, it would be entirely consistent with the purposes of the Compulsory Process Clause simply to exclude the witness's testimony"
- holding that the compulsory process clause of the Sixth Amendment permits exclusion of testimony of a defense witness as a sanction for violating a discovery rule because it was “reasonable to presume that there is something suspect about a defense witness who is not identified until after the 11th hour has passed”
- finding that exclusion of evidence proper where counsel’s explanation for intentionally failing to disclose evidence was “motivated by a desire to obtain a tactical advantage” that would “minimize the effectiveness” of the other party’s examination and their ability to adduce evidence in rebuttal
- explaining that the Court implicitly concluded that the petitioner’s Sixth Amendment claim was “sufficiently well presented to the state courts to support our jurisdiction . . . because the analysis in this case would essentially be the same under the Due Process Clause.”
Written by the judges who cited it.
Distinguished
Distinguished by Washington v. State, 840 N.E.2d 873 (2006)
Arguably, Taylor is distinguishable because the witness excluded in that case was not an alibi witness.
Distinguished by United States v. Ivory, 131 F. App'x 628 (2005)
Taylor is readily distinguishable and must be read against its facts.
Distinguished by People v. Corpas, 150 A.D.2d 710 (1989)
Apart from the fact that Escalera v Coombe (supra) was decided prior to the Supreme Court’s decision in Taylor v Illinois (supra), it is inapposite to the facts at bar.
The opinion
Justice Blackmun,
dissenting.
I join Justice Brennan’s dissenting opinion on the understanding — at least on my part — that it is confined in its reach to general reciprocal-discovery rules. I do not wish to have the opinion express for me any position as to permissible sanctions for noncompliance with rules designed for specific kinds of evidence as, for example, a notice-of-alibi rule. In a case such as that, the State’s legitimate interests might well occasion a result different from what should obtain in the factual context of the present case.