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Extraction Summary
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People
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Organizations
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Locations
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Events
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Quotes
Document Information
Type:
Legal document
File Size:
754 KB
Summary
This legal document, part of a court filing, argues that precluding certain statements is the only appropriate remedy for a discovery violation. It cites Federal Rule of Criminal Procedure 16(d)(2)(C) and legal precedents, including the Supreme Court's decision in *Taylor v. Illinois*, to establish that a court has the discretion to impose such a sanction. The argument rests on balancing a defendant's rights against public interests like the integrity of the trial process and the fair administration of justice.
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Supreme Court | Judicial body |
The Supreme Court’s decision in Taylor v. Illinois, 484 U.S. 400 (1988) is instructive.
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| 10th Cir. | Judicial body |
Mentioned in the citation for United States v. Wicker, 848 F.2d 1059, 1060 (10th Cir. 1988).
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Timeline (2 events)
1988
The Supreme Court issued a decision in the case of Taylor v. Illinois, which involved the exclusion of a witness as a sanction for a discovery violation.
Illinois
Locations (1)
| Location | Context |
|---|---|
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Mentioned in the case name Taylor v. Illinois.
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Relationships (1)
government
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Adversarial (Legal)
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defendant
The document discusses the legal dynamic between the government and a defendant in a criminal case, specifically regarding discovery obligations and potential prejudice from delays.
Key Quotes (2)
"to offer the testimony of witnesses in his favor"Source
— Supreme Court (in Taylor v. Illinois)
(Describing a defendant's fundamental right that must be balanced against countervailing public interests when considering a preclusion sanction.)
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Quote #1
"[t]he integrity of the adversary process, which depends both on the presentation of reliable evidence and the rejection of unreliable evidence, the interest in the fair and efficient administration of justice, and the potential prejudice to the truth-determining function of the trial process."Source
— Supreme Court (in Taylor v. Illinois)
(Listing the countervailing public interests that a trial court must consider when deciding on a preclusion sanction.)
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Quote #2
Full Extracted Text
Complete text extracted from the document (2,247 characters)
Case 1:20-cr-00330-PAE Document 384 Filed 10/29/21 Page 8 of 12
IV. Preclusion of the Purported Statements is the Only Appropriate Remedy
Fed. R. Crim. P. 16(d)(2)(C) provides that if a party fails to comply with the Court’s
orders regulating discovery the Court may prohibit that party from introducing the undisclosed
evidence as a sanction.
orders regulating discovery the Court may prohibit that party from introducing the undisclosed
evidence as a sanction.
A district court’s decision to impose a Rule 16(d)(2) sanction for the violation of a
discovery order, and thus its choice of sanction, is a matter committed to the Court’s sound
discretion. In exercising its discretion, the district court must weigh several factors, including the
reasons for the government’s delay in affording the required discovery, the extent of prejudice, if
any, the defendant has suffered because of the delay, and the feasibility of curing such prejudice
by granting a continuance. United States v. Wicker, 848 F.2d 1059, 1060 (10th Cir. 1988).
discovery order, and thus its choice of sanction, is a matter committed to the Court’s sound
discretion. In exercising its discretion, the district court must weigh several factors, including the
reasons for the government’s delay in affording the required discovery, the extent of prejudice, if
any, the defendant has suffered because of the delay, and the feasibility of curing such prejudice
by granting a continuance. United States v. Wicker, 848 F.2d 1059, 1060 (10th Cir. 1988).
The Supreme Court’s decision in Taylor v. Illinois, 484 U.S. 400 (1988) is instructive.
Taylor involved the exclusion of a witness of whom the defense had known but failed to
disclose. The defendant challenged the trial court’s exclusion of the witness as a sanction for the
discovery violation, alleging that it violated his right to present witnesses under the Sixth
Amendment’s compulsory process clause. In determining whether a preclusion sanction is
appropriate, the Court mandated that a trial court exercise its discretion by balancing a
defendant’s fundamental right “to offer the testimony of witnesses in his favor” against
countervailing public interests. Id. at 414. These interests include “[t]he integrity of the adversary
process, which depends both on the presentation of reliable evidence and the rejection of
unreliable evidence, the interest in the fair and efficient administration of justice, and the
potential prejudice to the truth-determining function of the trial process.” Id. at 414–15. The trial
court may also consider the willfulness of the violation, the simplicity of compliance with the
discovery obligation, and whether some unfair tactical advantage has been sought. See id. at
415–17. Considering these factors, the Court upheld the exclusion of the defendant’s witness.
Taylor involved the exclusion of a witness of whom the defense had known but failed to
disclose. The defendant challenged the trial court’s exclusion of the witness as a sanction for the
discovery violation, alleging that it violated his right to present witnesses under the Sixth
Amendment’s compulsory process clause. In determining whether a preclusion sanction is
appropriate, the Court mandated that a trial court exercise its discretion by balancing a
defendant’s fundamental right “to offer the testimony of witnesses in his favor” against
countervailing public interests. Id. at 414. These interests include “[t]he integrity of the adversary
process, which depends both on the presentation of reliable evidence and the rejection of
unreliable evidence, the interest in the fair and efficient administration of justice, and the
potential prejudice to the truth-determining function of the trial process.” Id. at 414–15. The trial
court may also consider the willfulness of the violation, the simplicity of compliance with the
discovery obligation, and whether some unfair tactical advantage has been sought. See id. at
415–17. Considering these factors, the Court upheld the exclusion of the defendant’s witness.
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