States are not specifically obligated to provide counsel in court. However, a court may appoint counsel or a guardian ad litem and frequently do so for requisition hearings in non-voluntary returns where there is a warrant pending, i.e. for accused delinquents, absconders, and escapees.
In regard to proceedings which may result in the revocation of parole or probation, a state should consider providing counsel to a juvenile offender if he or she may have difficulty in presenting their version of disputed facts, cross-examining witnesses, or presenting complicated documentary evidence.
Counsel is generally not provided when the juvenile is being retaken and the sending state does not intend to revoke conditional release based on violations that occurred in the receiving state. No liberty interest is at stake because the juvenile has no right to be supervised in another state.
References:
ICJ Bench Book: Chapter 4 Section 4.6.2
Rules 6-102, 6-103, and 6-103A