Question juridique clé
Whether the refusal of free legal representation in the administrative IV proceedings was lawful
Solution extraite
The refusal was lawful because the case was not exceptionally complex and did not require a lawyer.
Motifs extraits
Art. 37(4) ATSG requires legal aid in the administrative stage only in exceptional cases. The new application was a fairly ordinary case of changed health circumstances after a final denial; the medical file and language/ability issues did not make lawyer participation necessary.