Question juridique clé
Whether the appeal to the Federal Supreme Court was filed within the statutory time limit.
Solution extraite
The appeal was filed late because the cantonal decision was deemed served on 2011-12-02 and the appeal was lodged only on 2012-01-23.
Motifs extraits
Under Art. 44 Abs. 2 BGG, service is deemed effected after the unsuccessful first attempt; therefore the 30-day period under Art. 100 Abs. 1 BGG had expired.