Question juridique clé
Whether free legal representation had to be granted in the IV administrative procedure under Art. 37(4) ATSG.
Solution extraite
No. The case was not unusually complex, and the claimant’s language and administrative difficulties did not make counsel necessary.
Motifs extraits
Art. 37(4) ATSG requires strict cumulative conditions and a particularly strong need for counsel. A polydisciplinary medical assessment and a dispute over its evidentiary value were treated as an ordinary IV case; the claimant could rely on non-lawyer support or advisory services.