The Ninth Circuit has determined that an asylum seeker’s right to counsel was violated when the judge refused to continue a merits hearing that pro bono counsel could not be at due to a conflicting hearing. The decision has a good analysis of the difficulties of obtaining counsel for non-English speaking detainees.
The full decision in Usubakunov v. Garland can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2021/11/01/18-72974.pdf