In the case of Taylor v. Illinois, the U.S. Supreme Court ruled that a defendant's right to compulsory process does not include an absolute right to present witnesses who offer relevant and beneficial testimony for his defense if he fails to disclose their identities before trial as required by state law. The court held that such preclusion sanctions were permissible under certain circumstances in order to maintain integrity in the adversary system, ensure fair and efficient trials, and promote effective advocacy. In this case, defense counsel had deliberately withheld two alibi witnesses until just before trial with no explanation or excuse for failing to comply with discovery rules requiring witness disclosure prior to trial. The court found this conduct was designed solely for tactical advantage rather than any legitimate reason related to evidence gathering or preparation of a defense strategy.

In the dissenting opinion for Taylor v. Illinois, Justice Brennan argued that the majority's decision to allow trial courts to exclude defense witnesses as a sanction for discovery violations was an extreme measure that violated defendants' Sixth Amendment rights. He contended that this punishment was disproportionate and could potentially lead to wrongful convictions due to its severe impact on the defendant's right to present a full defense. Instead of completely barring testimony from undisclosed witnesses, he suggested less drastic remedies such as granting continuances or recesses, or instructing juries about late disclosures. Furthermore, he expressed concern over leaving too much discretion in judges' hands regarding when and how severely they should penalize discovery rule violators.