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Process Clause was the 1897 decision in Hovey v. Elliot. In Hovey, the Supreme Court specifically applied the Due Process Clause to fair trial guarantees, holding that due process "secures an 'inherent right of defense'". This doctrine eventually came to protect the defendant's ability to "present exculpatory evidence and testimony of witnesses". For example, the Court in Brady v. Maryland used the Due Process Clause to require the prosecution in criminal

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