Whether the appellant was entitled to court-appointed counsel for the appeal proceedings
The request was denied because, although indigence was established, the case was neither legally nor factually difficult enough and did not exceed the threshold of a minor case.
Under Art. 132 CPP, mandatory defense did not apply. For discretionary appointed counsel, indigence and the need to safeguard interests must both be met. The court found the appellant could handle the issues herself, and the alleged offense exposure remained within the range of a minor case.