According to quic-transport draft 28 section 10.3.1:
When sending CONNECTION_CLOSE, the goal is to ensure that the peer
will process the frame. Generally, this means sending the frame in a
packet with the highest level of packet protection to avoid the
packet being discarded. After the handshake is confirmed (see
Section 4.1.2 of [QUIC-TLS]), an endpoint MUST send any
CONNECTION_CLOSE frames in a 1-RTT packet. However, prior to
confirming the handshake, it is possible that more advanced packet
protection keys are not available to the peer, so another
CONNECTION_CLOSE frame MAY be sent in a packet that uses a lower
packet protection level.