The Ninth Circuit has determined that a non-citizen subject to a reinstatement order has a right to counsel in a reasonable fear review with an Immigration Judge. However, that right must be taken in the context of the regulation that requires that reasonable fear reviews be conducted within ten days of the issuance of the Asylum Officer’s negative reasonable determination. Thus, the agency did not deny the petitioner his right to to counsel when he requested time to find an attorney at his hearing, which was scheduled on Day 8 of 10.
The full text of Orozco-Lopez v. Garland and Gonzalez Martinez v. Garland can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2021/08/25/20-70127.pdf