Unfit for Trial, Barred from Review: Competency and Procedural Default After Yang

Competency to stand trial is a fundamental requirement of due process, yet federal courts remain divided on whether competency claims raised for the first time on collateral review may be procedurally defaulted. Some circuits exempt substantive competency claims on fairness grounds, while others subject all competency claims to default in the name of finality. Still, other courts distinguish between procedural and substantive claims. The Supreme Court has not resolved the question, leaving a fractured doctrine on an issue central to the legitimacy of criminal convictions. In 2024, in Yang v. United States, the U.S. Court of Appeals for the Seventh Circuit held that all competency claims are subject to procedural default and declined to recognize a distinction between procedural and substantive competency. This Comment argues that Yang is correct: a categorical rule better aligns competency with habeas doctrine, preserves systemic values of finality and efficiency, and still permits review of meritorious claims through established exceptions.