Question juridique clé
Whether the appellant was entitled to free legal representation in the cantonal child-protection appeal proceedings.
Solution extraite
Yes. The case was legally and factually complex, materially affected the appellant, and he could not reasonably conduct the proceedings unassisted.
Motifs extraits
The Federal Court held that the lower court underestimated the practical and legal difficulty of the proceedings and the appellant's overburdening risk; the appellant's close factual relation to the children also meant he was affected in a legally protected position.