Saunders v. Commissioner of Correction, 272 A.3d 169

Willie A. Saunders was convicted of first‑degree sexual assault and risk of injury to a child and did not raise incompetency at trial or on direct appeal.
In a subsequent habeas petition he alleged severe intellectual disabilities, epilepsy and serious mental‑health conditions and claimed he was incompetent to stand trial and that no competency evaluation was requested in violation of Conn. Gen. Stat. § 54‑56d.
The Commissioner pleaded procedural default; the habeas court granted the Commissioner’s motion to dismiss for failure to allege legally sufficient cause and prejudice, and the Appellate Court affirmed.
The Connecticut Supreme Court granted certification to decide (1) whether procedural default applies to competency claims and (2) whether Saunders sufficiently pleaded cause and prejudice to excuse the default.
The Supreme Court held procedural default does apply to competency claims but that incompetency can, if adequately pleaded and proved, satisfy the cause and prejudice standard; it reversed and remanded for an evidentiary hearing on competency and prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the procedural‑default doctrine apply to claims that a defendant was incompetent to stand trial?	Saunders: competency claims cannot be waived and thus should be exempt from procedural default; federal precedent (e.g., Silverstein) supports non‑application.	Commissioner: procedural default applies; state interests in finality and uniformity require timely assertion of competency claims.	Court: Procedural default applies; finality/uniformity and forensic difficulties of retroactive competency inquiries support applying the doctrine.
Did Saunders adequately allege cause and prejudice to overcome procedural default?	Saunders: his allegations of severe cognitive and mental‑health impairments constituted an external objective cause and alleged prejudice (conviction and incarceration); prejudice can be shown by a reasonable probability the court would have found him incompetent and not restorable.	Commissioner: incompetency is an internal factor and therefore cannot establish cause; any competency claim must be tethered to ineffective assistance of counsel.	Court: Incompetency may be an external, legally cognizable cause; Saunders’s pleadings sufficiently alleged prejudice to survive dismissal and the case is remanded for an evidentiary hearing to determine competency and resulting prejudice.

Wainwright v. Sykes, 433 U.S. 72 (U.S. 1977) (establishes cause‑and‑prejudice procedural‑default framework)
Pate v. Robinson, 383 U.S. 375 (U.S. 1966) (court must hold competency hearing when bona fide doubt of competency exists)
Murray v. Carrier, 477 U.S. 478 (U.S. 1986) (cause ordinarily requires an objective factor external to the defense)
Coleman v. Thompson, 501 U.S. 722 (U.S. 1991) (uniform application of cause and prejudice rule)
Silverstein v. Henderson, 706 F.2d 361 (2d Cir. 1983) (Second Circuit held competency claims not subject to procedural default)
Holt v. Bowersox, 191 F.3d 970 (8th Cir. 1999) (recognized severe mental illness may constitute cause to excuse default)
Drope v. Missouri, 420 U.S. 162 (U.S. 1975) (constitutional protection against trying an incompetent defendant)
Crawford v. Commissioner of Correction, 294 Conn. 165 (Conn. 2009) (Connecticut adopted cause‑and‑prejudice standard)
Hinds v. Commissioner of Correction, 321 Conn. 56 (Conn. 2016) (discusses procedural default, finality, and limited exceptions)
State v. Salamon, 287 Conn. 509 (Conn. 2008) (recognized a narrow exception to procedural default for Salamon claims)