What is the current state of the law on the right of a defendant to compel the attendance of a witness in a criminal case?

The Sixth Amendment guarantees that "[i]n all criminal prosecutions, the accused shall enjoy the right ... to have compulsory process for obtaining witnesses in his favor." The right to compulsory process includes "[t]he right to offer the testimony of witnesses, and to compel their attendance, if necessary, [and] is in plain terms the right to present the defendant's version of the facts as well as the prosecution's to the jury so it may decide where the truth lies." Washington v. Texas, 388 U.S. 14, 19 (1967).

"The defendant's right to offer the testimony of witnesses is not unbounded, however," United States v. Peters, 937 F.2d 1422, 1424 (9th Cir.1991), and preclusion of a witness' testimony may be a permissible sanction for a discovery violation. Taylor v. Illinois, 484 U.S. 400, 409 (1988).