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

The shooting victim identified the man he thought had shot him. During that man’s trial for attempted murder, the defendant tried to introduce some surprise witnesses, in violation of discovery rules. In Taylor versus Illinois, the United States Supreme Court considered whether the judge’s exclusion of that testimony violated the Sixth Amendment’s Compulsory Process Clause.

Ray Taylor got into an argument with Jack Bridges that progressed into a street fight involving multiple participants. A man shot at Bridges several times, striking him in the back. The man then placed the gun at Bridges’ head and pulled the trigger, but the gun misfired. Bridges claimed it was Taylor who shot at him.

Taylor was tried for attempted murder. Two sisters who had been sitting across the street from the incident testified that it was actually Taylor’s brother who shot Bridges. After the prosecution’s witnesses had testified, Taylor’s attorney moved to add two more defense witnesses. Illinois rules required a defendant to respond to the state’s motion for discovery by providing a list of intended witnesses within a reasonable time, but the attorney explained that Taylor hadn’t been able to find the witnesses earlier. The court heard testimony from one of them, Alfred Wormley, outside the presence of the jury. Wormley’s testimony didn’t correspond to what Taylor had claimed he would say, and it was clear that he hadn’t even witnessed the event. In fact, he’d first met Taylor two years after the shooting incident. The trial judge concluded that Wormley’s testimony was unreliable. The judge also held that Taylor’s attorney had violated the discovery rules, and that the appropriate sanction was to exclude Wormley’s testimony.

Taylor was convicted of attempted murder. The Appellate Court of Illinois upheld the conviction. Taylor appealed, arguing that the Sixth Amendment creates an absolute bar to the preclusion of testimony by a surprise witness.

The United States Supreme Court granted certiorari.

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