Kernrechtsfrage
Whether appointed defense had to be granted under Art. 132 StPO in the customs criminal proceedings
Extrahierter Entscheid
No. The case was a minor offense with only a fine of CHF 6,200 expected, and no special factors made self-representation unreasonable.
Extrahierte Begründung
Under Art. 82 VStrR, Art. 132 StPO applies. A minor case excludes appointed defense unless special factual or legal difficulties exist. A fine of CHF 6,200 remains below the statutory threshold; conversion to detention would still not exceed three months under Art. 10 Abs. 3 VStrR.