Question juridique clé
Whether the refusal to appoint ex officio counsel in the criminal complaint proceedings violated constitutional rights or was arbitrary application of cantonal law.
Solution extraite
The refusal was not arbitrary; the conditions for exceptional appointment of counsel were not met.
Motifs extraits
The applicant was not a victim under the federal victims' assistance act. Under cantonal law, counsel may exceptionally be appointed to a civil party in criminal proceedings only if the accused has a defender and the case is not otherwise simple. Those conditions were absent, so the cantonal decision was sustainable under Article 9 of the Constitution.