Question juridique clé
Whether the refusal of legal aid and appointment of counsel in the criminal case violated Art. 29(3) Cst.
Solution extraite
No. Given the limited severity of the sanction and the absence of particular factual or legal difficulty, the appellant had no constitutional right to court-appointed counsel.
Motifs extraits
The conviction did not involve a custodial sentence or equivalent serious restriction of personal liberty. In such a case, legal aid depends mainly on the complexity of the matter. The cantonal court’s finding that the case was not particularly difficult was not challenged convincingly, and the asserted ethical obstacle to self-representation was not substantiated.