The inclusion of the compulsory process clause in the Bill of Rights merely affirmed an unquestioned right that had existed in the colonial era. The clause was the subject of important judicial inquiry and interpretation in the early history of the United States and then was generally ignored for more than 150 years. However, in recent years the right to compulsory process has become a focus of attention, mainly because of the Supreme Court's conclusion that the Fourteenth Amendment makes the clause applicable to the States. Issues that remain unresolved include the confrontation between this clause and the government's interest in protecting State secrets, the admission of hypnotically refreshed testimony from witnesses other than the defendant, the extent to which the clause permits the exclusion of a defendant's evidence as a discovery sanction, and a media reporter's obligation to respond to process issued by a defendant. 151 footnotes.