dissenting:
The plurality’s interpretation of Federal Rule of Evidence 615, which would create an attorney exception to the rule, is contrary to precedent and common sense. In misconstruing the rule, the plurality would substantially frustrate its purpose and effect.
Because I believe that the district court’s interpretation of Rule 615 was reasonable and consistent with the customary interpretation of the rule and that the court’s finding that counsel for the defendant violated the rule is supported by the record, I would affirm the district court’s conclusion that counsel violated its sequestration order. With respect to the remedy, while I believe that the court, in the exercise of its discretion, might have better articulated its consideration of the full range of available sanctions before excluding the witness’ testimony, for the reasons given by Chief Judge Wilkinson, I conclude that the exclusion of the witness’ testimony fell within the discretion conferred upon district courts to administer Rule 615.
I
At the outset of this criminal trial, counsel for one of the seven defendants in this case invoked Federal Rule of Evidence 615 to have witnesses sequestered during trial. Accordingly, the district court stated in open court:
Well, I do grant the usual sequestration rule and that is that the witnesses shall not discuss one with the other their testimony and particularly that would apply to those witnesses who have completed testimony not to discuss testimony with prospective witnesses, and I direct the Marshal’s Service, as much as can be done, to keep those witnesses separate from the — those witnesses who have testified separate and apart from the witnesses who have not yet given testimony who might be in the custody of the marshal.
In presenting Michael Rhynes’ defense, Rhynes’ counsel, Michael Scofield, called Corwin Alexander as a witness. Alexander was questioned about D.S. Davis, a witness who had testified during the government’s case. In the course of answering these questions, Alexander began to relate his understanding of what Davis had testified to earlier in the trial. When the government objected on the ground that the court’s sequestration order had been violated, the following dialogue took place:
The Court: I’d like to know how he heard that because everyone in this courtroom was instructed not—
Mr. Scofield: Because I discussed his testimony with him. I specifically told him about that testimony and told him I was going to ask him about that,
Your Honor. . I don’t think that violates the sequestration order.
*333The Court: Certainly does.
* * * * # *
The Court: It’s very unprofessional. It’s an absolute breach of Rule 615, and I don’t see how you think you can get by that just because you think you are preparing a witness.
Mr. Scofield: Well, I have to ask him about it. I want to ask him about it on direct.
Government Attorney: Seems to me the proper way to prepare the witness is the way the government prepared. We ask what they know. We don’t tell them what went on in the courtroom.
The court thereupon struck Alexander’s testimony.
Following the afternoon recess, Scofield approached the bench and acknowledged a violation of the Rule:
Your Honor, as I told you in chambers, I now realize that the proper thing for me to do in interviewing Alexander and preparing him to testify was that I could have asked him all the details of whether he had been a dealer and whether he had done drug deals with Michael Rhynes and that, sort of thing without telling him that Davis had said that he had done that.
Scofield then explained that he had related the government witness’ testimony to Alexander in order to elicit Alexander’s response to it. He also proffered the remainder of Alexander’s testimony. The court thereupon concluded:
I am not going to revisit that issue. And I would have to say that your proffer about all the information that Mr. Alexander has about witnesses who have testified in this trial would certainly lead this judge to conclude that my Rule 615 order was violated as to the testimony of many witnesses.
‡ ‡ ‡
[T]he only thing you lose is the testimony of this witness, who has been obviously coached on testimony that’s been given in this courtroom under a separation of witness rule. And that is wrong, sir.
The sanction is reasonable under the circumstances. I’ve held the government’s feet to the fire, and it was the defense that suggested that the government observe that ruling at the beginning of the trial.
Scofield thereafter assured the court that he violated the order only in repeating to Alexander the testimony of government witness Davis.
The sole question raised on this appeal en banc is whether the district court’s exclusion of Alexander’s testimony constituted reversible error. The plurality would hold that Rule 615 does not prohibit counsel for the parties from discussing the testimony of prior witnesses with prospective witnesses because “nothing on the face of [Rule 615] addresses the conduct of lawyers in any way.” Ante at 315. The plurality would hold further that the demands of attorney preparation, ethics, and constitutional provisions require that the rule permit attorneys to discuss the testimony of prior witnesses with prospective witnesses in preparing them for trial. It adds that if a witness is inappropriately coached, the remedy is through cross-examination, thus eviscerating, in essence, the proscription of Rule 615 as it applies to attorneys.
The government argues on appeal that the “serious and dangerous nature of this argument cannot be overstated. If attorneys are allowed to conduct themselves in a manner that undermines the purpose of court orders, those orders and our function as ‘officers of the Court’ are rendered meaningless.” The government notes that excusing defense counsel from compliance with sequestration orders would subject rulings of trial courts to “the word games so popular in our public life today. We believe this Court should not countenance those games at the expense of justice, *334truth and the proper functioning of our court system.”
For the reasons that follow, I heartily agree with the government’s position. The plurality’s opinion would be without precedent and would all but render Rule 615 a hollow shell, since attorneys try virtually all cases in which a Rule 615 order is imposed. Under the plurality’s holding, attorneys could legally undermine sequestration orders simply by acting as “go-betweens,” relating to prospective witnesses what has already been testified to by other witnesses.
II
The operative language of Federal Rule of Evidence 615 reads: “At the request of a party the court shall order witnesses excluded so that they cannot hear the testimony of other witnesses, and it may make the order of its own motion.” This rule is designed to discourage and expose fabrication, inaccuracy, and collusion by limiting the ability of one witness to shape his testimony to match that given by other witnesses at trial. See Opus 3 Ltd. v. Heritage Park, Inc., 91 F.3d 625, 628 (4th Cir.1996). The rule is one of the most important trial mechanisms for reaching truth. Indeed, it is recognized that the sequestration of witnesses is “one of the greatest engines that the skill of man has ever invented for the detection of liars in a court of justice.” Id. (quoting 6 John Henry Wigmore, Wigmore on Evidence § 1838, at 463 (James H. Chadbourn ed., 1976)). The mechanism is not a creation of Rule 615, but represents the wisdom of the ages. In the book of Susanna, in the Apocrypha, Susanna of Biblical times was charged with adultery, for which the penalty was death. Daniel, suspecting complicity between the two prosecutorial witnesses, issued this order: “Separate [the witnesses] far from each other, and I will examine them.” Apocrypha, Susanna, v. 51 (New Rev. Standard Version). When the process revealed material discrepancies in the witnesses’ stories, Susanna was acquitted and the witnesses were beheaded for giving false testimony. Professor Wigmore, characterizing the pedigree and importance of the sequestration rule, states, “There is perhaps no testimonial expedient which, with as long a history, has persisted in this manner without essential change.” 6 Wigmore on Evidence § 1837, at 457.
While the express directive of Rule 615 — that witnesses be “excluded so that they cannot hear the testimony of other witnesses” — suggests most immediately the exclusion of witnesses from the courtroom, it has always been understood also to preclude the discussion among witnesses of testimony that has taken place in the courtroom. Common sense commands that if a rule prohibits a witness from “hearing” the testimony of other witnesses, the prohibition is violated if the testimony of a prior witness is repeated and heard in the courthouse corridor or outside on the street. As Professor Wig-more points out, a sequestration of witnesses of necessity includes requirements that (1) prospective witnesses not consult with each other; (2) one witness not listen to the testimony of another; and (3) a witness who has left the stand not consult with a prospective witness. See 6 Wig-more on Evidence § 1840, at 471.1 While *335Professor Wigmore recognizes that a trial judge may relax these requirements in the court’s discretion, he admonishes that “nothing should sanction any indirect method of conveying to the prospective witnesses information of the testimony already given. For example, it would seem obvious to good sense that the perusal of journals reporting the testimony should be forbidden.” Id. at 471-72.
Even the plurality acknowledges that the sequestration of witnesses under Rule 615 requires that witnesses “not discuss the case among themselves or anyone else-” Ante at 317. Indeed, the Supreme Court has recognized this prohibition not only as “common practice,” but also as a “corollary” of Rule 615. Perry v. Leeke, 488 U.S. 272, 281, 109 S.Ct. 594,102 L.Ed.2d 624 (1989). The Court noted that the rule is enforced “to lessen the danger that [witnesses’] testimony will be influenced by hearing what other witnesses have to say, and to increase the likelihood that they will confine themselves to truthful statements based on their own recollections.” Id. at 281-82, 109 S.Ct. 594. Thus, the common understanding is that the prohibition against “hearing” what other witnesses have stated in the courtroom extends to the learning of testimony outside of the courtroom. We explicitly recognized this in United States v. McMahon, 104 F.3d 638 (4th Cir.1997), where we upheld the contempt conviction of a witness, who was subject to a Rule 615 sequestration order, for reading daily trial transcripts and sending his secretary to the courtroom to find out what was transpiring. The order in McMahon was the most simple invocation of Rule 615: “The Government’s motion to sequester the Defendant’s witnesses will be granted, and the Defendant’s witnesses will be excluded from the courtroom.” 104 F.3d at 640; see also Miller v. Universal City Studios, Inc., 650 F.2d 1365, 1373 (5th Cir.1981) (holding that Rule 615 prohibits the reading of trial transcripts); State v. Steele, 178 W.Va. 330, 359 S.E.2d 558, 562 (1987) (listening to “mechanical recordings” of courtroom testimony violates sequestration order). As the Fifth Circuit explained in Miller, “The opportunity to shape testimony is as great with a witness who reads trial testimony as with one who hears the testimony in open court.” 650 F.2d at 1373.
While the plurality does not seem to take issue with the notion that Rule 615 prohibits one witness from speaking with another witness or with anyone else, it would hold that a witness may discuss with an attorney the testimony of another witness: “This Rule’s plain language relates only to “witnesses’.... Thus, Rule 615 did not prohibit Mr. Scofield from discussing D.S. Davis’s testimony with Corwin Alexander.” Ante at 315. As the plurality observes, “nothing on the face of [Rule 615] addresses the conduct of lawyers in any way.” Ante at 315.
This observation is remarkable in two respects. First, a rule that prohibits a witness from “hearing” the testimony of other witnesses must include a prohibition against hearing that testimony not only from another witness directly but also through intermediaries. This is a necessary conclusion, as the plurality acknowledges. And second, if Rule 615 precludes a person from acting as an intermediary to relate to one witness the testimony of another, how can we exempt an attorney from the proscription? Just as a discussion among witnesses outside the courtroom would frustrate the rule that one witness cannot hear the testimony of another, a discussion between a witness and an attorney about another witness’ testimony frustrates the rule. This is the specific holding of the Fifth Circuit in Jerry Parks Equip. Co. v. Southeast Equip. Co., Inc., 817 F.2d 340 (5th Cir.1987). In that case, the party and its counsel met with *336the witness during lunchtime. The court not only found a violation of Rule 615, but also, because the party’s attorneys were involved, upheld the district court’s exclusion of the witness’ testimony. See id. at 342-43. The Supreme Court cited this case with approval in Perry v. Leeke, invoking it as an example of the “common practice” under Rule 615 and summarizing it as involving the “improper discussion of [a] case by defense witness with defense counsel.” 488 U.S. at 281 & n. 4, 109 S.Ct. 594.
Thus, while the plurality seems to en7 dorse an interpretation of Rule 615 that would prohibit witnesses from discussing testimony among themselves or with anyone else, it maintains that the “someone else” does not mean an attorney and that somehow an attorney has a license to violate the proscription and frustrate the rule. Stated otherwise, while two witnesses are prohibited from discussing testimony with each other directly, they may conduct such a discussion through the ears and mouth of an attorney. This conclusion is neither logical nor supported by precedent.2
To be sure, the cases and text relied upon by the plurality acknowledge that attorneys may discuss “the case” with witnesses, but this observation does not suggest that the attorneys may, in the face of a sequestration order, relate to a prospective witness the testimony that • a prior witness has given. The plurality rationalizes its attorney exception on three bases. First, “[tjhorough preparation demands that an attorney interview and prepare witnesses before they testify. No competent lawyer would call a witness without appropriate and thorough pre-trial interviews and discussion.” Ante at 319. But it does not follow from this observation that an attorney cannot fulfill this duty of diligence without violating a sequestration order. The attorney may review facts and arguments with the witness, but the attorney should not be complicit in shaping testimony and matching it with the testimony of other witnesses.
Second, the plurality suggests that the attorney in this case “had ethical (and possibly constitutional) duties to investigate [Davis’] allegations with Alexander before he put Alexander on the stand.” Ante at 319. Again, however, the attorney could have fulfilled those duties by asking Alexander what he knew of the events about which he was going to testify. But relating to Alexander the testimony of a prior witness allowed Alexander to “hear” the testimony of that prior witness, directly in violation of Rule 615.
Finally, acknowledging that an attorney exception to Rule 615 would permit attorneys to “coach” witnesses, the plurality seeks to provide assurance by identifying other truth-seeking mechanisms: “[Ijf an attorney has inappropriately ‘coached’ a witness, thorough cross-examination of that witness violates no privilege and is entirely appropriate and sufficient to address the issue.” Ante at 320.
The lofty purpose of Rule 615 deserves greater deference than it would be given if it were allowed to be engulféd by an attorney exception for trial preparation. And the rule is forfeited altogether by arguing that even though the truth-seeking purpose of Rule 615 might be debased by an attorney exception, cross-examination will fill the gap. The rule is'given, and we ought to enforce it. And it is totally inconsistent with the “common practice” under the rule to allow an attorney to tell a prospective witness what a prior witness *337has said on the witness stand. The attorney in this case heard the order from the court, and by telling a prospective witness about the testimony of a prior witness, the attorney directly violated the court’s order.
Ill
For the reasons given by Chief Judge Wilkinson, I find that the district court’s order excluding the testimony of Alexander did not constitute an abuse of discretion. See Jerry Parks, 817 F.2d at 342-43. Accordingly, I would affirm.
I am authorized to indicate that Chief Judge Wilkinson joins in this opinion and that Judge Traxler joins in Parts I and II of the opinion affirming a violation of the district court’s sequestration order.
. Judge King suggests an absence of any authority for the proposition that when Rule 615 is invoked, "a witness [is prohibited] from heating, in any form whatsoever, anything contained in a prior witness's testimony.” Ante at 315 n. 6. As I further develop this point below, I note at this point, only to respond to Judge King, that Rule 615 itself provides for sequestration "so that [witnesses] cannot hear the testimony of other witnesses.” Fed.R.Evid. 615 (emphasis added). While the purpose of Rule 615 in preventing witnesses from "hearing” the testimony of prior witnesses is not limited in the Rule to any particular location, were there any doubt, our own precedent holds that "hearing” includes the reading of testimony outside of the courtroom. See United States v. McMahon, 104 F.3d 638 (4th Cir.1997). This is a universally understood reading of the Rule. See, e.g. Perry *335v. Leeke, 488 U.S. 272, 281, 109 S.Ct. 594, 102 L.Ed.2d 624 (1989); Miller v. Universal City Studios, Inc., 650 F.2d 1365, 1373 (5th Cir.1981); State v. Steele, 178 W.Va. 330, 359 S.E.2d 558, 562 (1987).