Question juridique clé
Whether the refusal to appoint ex officio counsel violated Art. 29 para. 3 Constitution
Solution extraite
No. The case was not shown to be particularly complex, and the penalties faced were not sufficiently grave to require mandatory appointment.
Motifs extraits
Under Art. 29 para. 3 Cst., counsel is required when protection of rights so demands; in criminal cases this depends on the seriousness of the potential sanction and the concrete factual and legal difficulty. The appellant did not demonstrate special complexity, and a future renewed request remained possible if the investigation became more difficult.