The Eleventh Circuit has declined to address whether a petitioner has a right to counsel during an immigration judge’s review of a negative reasonable fear determination. In this case, the petitioner had been issued a final order of administrative order of removal due to an aggravated felony conviction. The court instead determined that even if such a right exists, the petitioner must show substantial prejudice stemming from the violation of that right, and the petitioner failed to do so in this case.
The full text of Priva v. Attorney General can be found here:
https://media.ca11.uscourts.gov/opinions/pub/files/202012521.pdf