 The impact of Washington was narrowed by a later case , Taylor v. Illinois ( 1988 ) , in which the Court said that " countervailing public interests " , like the need to move through cases quickly , could be balanced against a defendant 's right to present witnesses . In Taylor , the Supreme Court upheld a judge 's order blocking defense witnesses from testifying due to the defense attorney 's deliberate failure to disclose evidence to prosecutors earlier in the trial . The defense attorney 's actions resulted in a lengthy delay in the proceedings which the trial judge felt was unjustified . Legal scholars have seen this new grant of discretion to trial judges as a change to relying on " efficient justice " , a more limited vision of trial rights than the " right to present a defense " created in Washington . 
