Question juridique clé
Whether the refusal to appoint legal counsel in the cantonal appeal violated the right to judicial assistance under art. 118 CPC
Solution extraite
No. The case was not particularly complex, the applicant could defend his interests adequately, and the adult-protection authority was not an opposing party.
Motifs extraits
Under art. 117-118 CPC, counsel is appointed only when defense of rights requires it, especially if the opposing party is represented. Here the authority acts ex officio and the applicant's own submissions showed he was able to proceed without counsel.