Saturday, April 13, 2013

Taylor v. Illinois case brief

Taylor v. Illinois case brief summary
484 U.S. 400 (1988)

CASE SYNOPSIS:
Petitioner sought review of a decision by the Appellate Court of Illinois affirming petitioner's conviction for the offense of attempted murder.

OVERVIEW:
-On the second day of trial, petitioner's counsel made an oral motion to modify his witness list.
-After an extensive colloquy, the trial judge determined that a surprise witness's testimony contradicted petitioner's counsel's representations.
-The trial judge concluded that the appropriate sanction was to exclude that testimony.
-Petitioner contended that the U.S. Const. amend VI created an absolute bar to the preclusion of the testimony of a surprise witness. The Court affirmed the judgment of conviction because the Compulsory Process Clause of the U.S. Const. amend. VI would have been demeaned if it was construed to encompass an absolute right present exculpatory evidence.

HOLDING:
The Court held that if the explanation regarding the surprise witness revealed that the omission 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, exclusion of the witness would be entirely justified.

ANALYSIS:
Accordingly, the Court further found that facts of the case justified the sanction of preclusion.

OUTCOME: Appellate court's judgment affirming petitioner's conviction for attempted murder was affirmed because the Court found that there was no absolute bar to the preclusion of the testimony of a surprise witness presented at the 11th hour of a trial and under the circumstances of the case the sanction of precluding the witness was justified.

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