The Ninth Circuit has held that an individual expeditiously removed by Customs and Border Protection has no right to counsel during the expedited removal process. This analysis focuses heavily on the idea that expedited orders of removal only apply to individuals who cannot prove they have been present in the United States for 14 days, and thus, not to individuals with strong ties to the United States. In light of the Trump administration's proposal to expand expedited orders of removal to individuals who cannot prove 2 years of presence in the United States, this finding may be up for review again quite soon.
The court declined to determine if a failure to advise an individual of their right to withdraw their application for admission in expedited removal proceedings violates due process, finding that the petitioner could not prove that it was plausible that such relief would have been granted.
The full text of US v. Peralta-Sanchez can be found here:
http://cdn.ca9.uscourts.gov/datastore/opinions/2017/02/07/14-50393.pdf