Sabrina Damast has recently obtained a published decision from the Ninth Circuit Court of Appeals, affirming the right to counsel for non-citizens subject to a reinstated order of removal during their reasonable fear review with an Immigration Judge.
The text of Gonzalez Martinez v. Garland can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2021/08/25/20-70127.pdf