In Taylor v. Illinois, 484 U.S. 400 (1988), a case involving the violation of a pre-trial discovery order, the United States Supreme Court held that the compulsory process clause is not merely a guarantee that the accused shall have the power to subpoena witnesses, but confers on the accused the fundamental right to present witnesses in his own defense. Taylor further held, however, that although a trial court may not ignore a defendant's fundamental right to present witness testimony in his favor, the mere invocation of that right cannot automatically and invariably outweigh countervailing public interests. Id. at 410-16. The factors to be weighed in the balance include, but are not limited to the "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. In Taylor v. Illinois, the trial court excluded a defense witness's testimony because his name had not been produced until the second day of trial after the prosecution's two principal witnesses had completed their testimony. 484 U.S. at 403. The court held that a trial judge's refusal to allow an undisclosed witness to testify was not prohibited by the Compulsory Process Clause of the Sixth Amendment. Id. 416. The court justified the use of sanctions stating that one of the purposes of discovery rules is to minimize the risk of fabricated testimony. Id. 413. The court stated that it is "reasonable to presume that there is something suspect about a defense witness who is not identified until after the 11th hour has passed." Id. 414. In sum, The United States Supreme Court has upheld discovery sanctions when a party intentionally violates a reciprocal discovery rule in order to gain a "tactical advantage." The United States Supreme Court stated that when "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, it would be entirely consistent with the purposes of the Compulsory Process Clause to exclude the witness' testimony." 484 U.S. at 415. In Taylor, the defendant's attorney did not disclose one witness until the second day of trial even though he had been in contact with him for at least a week prior to that and had amended his discovery to add two other witnesses on the first day of trial. The trial court found that it was a blatant and willful violation of the discovery rules and excluded the witness. A divided Supreme Court affirmed.