Questione giuridica chiave
Whether the cantonal judgments were void for lack of mandatory defence and whether the 2005 Horgen judgment could be challenged as void
Decisione estratta
No voidness was shown; mandatory defence was not required on the concrete sentencing exposure, and the 2005 judgment could not be attacked in this federal appeal.
Motivazione estratta
Mandatory defence depends on the concrete expected total custodial exposure, including any revocation. Here the expected total was 11 months, below the threshold. The appellant also caused his lack of counsel and did not show any other grave procedural defect.