In the case of Taylor v. United States in 1973, the Supreme Court ruled that a defendant's right to due process was not violated when he was denied access to government files on potential witnesses for his defense. The petitioner, Taylor, had been convicted of bank robbery and sought access to FBI files on two key prosecution witnesses who were also involved in the crime but had received immunity from prosecution in exchange for their testimony against him. He argued that these records could contain information useful for impeaching their credibility. However, the court held that there is no general constitutional right to discovery in criminal cases and affirmed its previous rulings stating defendants are not entitled to inspect government documents before trial unless they can show those documents are material both to guilt and punishment.

In the dissenting opinion for Taylor v. United States, Justice Douglas argued that the majority's decision to uphold a conviction based on circumstantial evidence was problematic. He contended that there was insufficient proof beyond reasonable doubt that Taylor had knowledge of stolen goods in his possession, which is necessary for a conviction under federal law. The only evidence presented against him were two checks found in his car and testimony from an accomplice who admitted lying previously about related matters. Douglas believed this did not meet the standard required by law and expressed concern over potential miscarriages of justice if convictions could be upheld with such weak evidentiary support.