 In two cases after Washington , the Court pulled back from its broad principle that a defendant in a criminal proceeding has a " right to a defense " . In United States v. Valenzuela @-@ Bernal ( 1982 ) , the Court held that an argument by the government that it had an interest in deporting illegal aliens ( some witnesses in the case ) outweighed the defendant 's right to " eye witness testimony " . Additionally , in Taylor v. Illinois ( 1988 ) , the Court held that " countervailing public interests " could also outweigh the defendant 's compulsory process rights . 
