 However, in 1971, the Ninth Circuit, applying principles of "Washington v. Texas", reversed and held that the government's decision to deport the four illegal aliens before obtaining a testimony not only violated the defendant's due process guarantee, but his compulsory process rights as well.This decision provided the prevailing attitude for cases involving illegal alien witnesses in relation to the compulsory process clause until the Supreme Court's decision in "United States v. Valenzuela-Bernal".The “essential elements” stated in "US v. Mendez-Rodriguez" were also summarized by the Court of Appeals’ opinion in "United States v.