Appointed Counsel for Immigrants?

 
Mark Noferi (Brooklyn) has a recent op-ed in the New York Law Journal interesting for the ImmProf Blog. The op-ed argues that the recent U.S. Supreme Court case Turner v. Rogers, which considered the right to appointed counsel in civil cases where incarceration is at issue, supports a right to appointed counsel for immigrant detainees in the future.

Is appointed counsel the next step to protect immigrants facing removal after the Supreme Court's decision in Padilla v. Kentucky?

KJ