BIA on Incompetent Respondents: Matter of E-S-I-, 26 I&N Dec. 136 (BIA 2013)

(1) Where the indicia of a respondent’s incompetency are manifest, the Department of Homeland Security (“DHS”) should serve the notice to appear on three individuals: (1) a person with whom the respondent resides, who, when the respondent is detained in a penal or mental institution...