Taylor was the first Compulsory Process Clause case since Washington v. Texas to provide a specific limitation on the right of defendants to force their witnesses to testify.

[8] The decision articulated the "two-way street" approach, that "trials be run as a 'search for truth'" without either side maintaining "'poker game' secrecy for its own witnesses".

[9] Along with these decisions that were specific to the discovery process, the Supreme Court broadened the general constitutional rights for defendants in the 1967 ruling of Washington v. Texas.

In Washington, the Court incorporated the Compulsory Process Clause against the states, holding that "the Constitution is violated by arbitrary rules that prevent whole categories of defense witnesses from testifying".

[19] Justice John Paul Stevens wrote the opinion, which affirmed the decision of the Illinois Appellate Court, and upheld Taylor's conviction.

He began by addressing the position of the state of Illinois, who argued that there is never a Compulsory Process Clause concern when preclusion of a witness is used as a discovery sanction.

[23] In the instant case, the Court held that a trial judge could hold the "presumption" that a new witnesses' testimony is perjured due to "a pattern of discovery violations".

[25] "It would demean the high purpose of the [Clause] to construe it as encompassing an absolute right to an automatic continuance or mistrial", Stevens wrote.

[21] As the misconduct of the judge towards the defense counsel did not implicate the Sixth Amendment's Compulsory Process Clause, there was no need to disrupt the lower courts' decisions.

[29] He went on to argue that simple preclusion of a defense witness was too extreme a penalty for a discovery violation, to the point that it "subverts criminal justice by basing convictions on a partial presentation of the facts".