The Ninth Circuit has determined that the agency must only reference a petitioner’s mental illness during a particularly serious crime analysis if the petitioner presents evidence attributing the crime to mental illness. The court also determined that the agency was not required to terminate proceedings for a mentally ill petitioner who physically attacked his qualified representative and who refused to cooperate in any document collection efforts made by his representative.
The full text of Benedicto v. Garland can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2021/09/09/18-73237.pdf