Saunders v. Commissioner of Correction

Summary

The court held that due process claims alleging incompetency to stand trial are subject to procedural default, because the interests in finality, uniformity, timely resolution, and reliable competency determinations apply equally to those claims. It nevertheless held that alleged incompetency may constitute external cause and that the petitioner sufficiently pleaded prejudice by alleging that a timely evaluation would have shown that he was incompetent and not restorable to competency. The judgment was reversed and the case was remanded for an evidentiary hearing on competency, cause, and prejudice.