Mohammed

MEMORANDUM

Petitioner Ibrahim Ibssa Mohammed, a citizen of Ethiopia, brings these consolidat ed petitions for review of two orders of the Board of Immigration Appeals (“BIA”). In the first order, the BIA adopted and affirmed the decision of the Immigration Judge (“IJ”) concluding that Mohammed’s conviction for “robbery” under Arizona Revised Statutes § 13-1902 constituted a “particularly serious crime,” making Mohammed ineligible for asylum and withholding of removal, and that Mohammed failed to meet his burden for protection under the Convention Against Torture (“CAT”). Petitioner’s first petition to this court challenged this decision of the BIA.

Mohammed filed a motion to reopen, alleging, among other things, that he was incompetent to proceed pro se, and as a result, that the proceedings before the IJ lacked due process. He also claimed that evidence of his mental illness undermined the IJ’s determination that he was convicted for a particularly serious crime. The BIA denied the motion. Petitioner’s second petition to this court challenged this denial.

We deny the first petition for review. We grant in part the second petition for review, reversing the denial of the motion…