4. – Decisions of the social courts on social assistance (SGB XII)
4.1 – Social Court Aachen, Judgment of 20 January 2012, - S 19 SO 108/11 -, Appeal allowed
New standard rates are constitutional
In its judgment of February 9, 2010 (Case No. 1 BvL 1/09 et al. = BVerfGE 125, 175 et seq.), the Federal Constitutional Court stated that, in order to specify the legal entitlement to a guaranteed minimum standard of living derived from Article 1 Paragraph 1 of the Basic Law in conjunction with the social state principle of Article 20 Paragraph 1 of the Basic Law, the legislature must logically measure all essential subsistence expenses in a transparent and appropriate procedure according to actual need, i.e., realistically.
To this end, he must first determine the types of needs and the associated costs, and on this basis determine the total amount of the need. The Basic Law does not prescribe a specific method for this; rather, he may choose one himself within the bounds of suitability and appropriateness (Federal Constitutional Court, loc. cit. = juris para. 139).
In this decision, the Federal Constitutional Court further emphasized the procedural dimension of the fundamental right to a dignified minimum standard of living. This necessitates a review of the basis and method of benefit calculation to ensure they meet the objective of this fundamental right. Benefit determinations must be justifiable on the basis of reliable figures and sound calculation methods (Federal Constitutional Court, loc. cit., para. 142 et seq.). However, the legislature's discretion in determining the minimum standard of living must be respected.
For the purposes of constitutional review, this means that the statutory provision can only be reviewed to determine whether the legislature has chosen a suitable calculation method, whether it has ascertained the necessary facts essentially completely and accurately, and finally, whether it has acted within the bounds of what is justifiable in all calculation steps, using comprehensible figures within this chosen method and its structural principles. To enable this review, the legislature is obligated to disclose in a comprehensible manner the methods and calculation steps used to determine the subsistence minimum during the legislative process (Federal Constitutional Court, loc. cit., para. 143 et seq.).
The Federal Constitutional Court considers the procedure underlying the old law for determining the subsistence minimum to be fundamentally suitable for realistically assessing the benefits necessary to secure a dignified subsistence minimum (Federal Constitutional Court, loc. cit., para. 159 at the end). The statistical model applicable under Section 2 of the Standard Rate Ordinance 2005 is a constitutionally permissible, because justifiable, method for determining the subsistence minimum for a single person (Federal Constitutional Court, loc. cit., para. 162).
With regard to the amount of €311 for adult partners in a household receiving social assistance, as stipulated in Section 20 Paragraph 3 Sentence 1 of the German Social Code, Book II (SGB II aF), the legislator was entitled to assume that joint management of finances would result in savings and that, therefore, two partners living together have a minimum financial need that is less than twice that of a single person managing their finances alone. Since, due to their cohabitation, it can be assumed that both partners are managing their finances "from a single pool," it is not objectionable that the legislator has set the same amount of need for both partners (Federal Constitutional Court, loc. cit., para. 154).
However, the standard benefit of (formerly) 345 euros was determined in an unconstitutional manner because the structural principles of the statistical model chosen by the legislator itself were deviated from without objective justification (Federal Constitutional Court, loc. cit., para. 173 ff.).
Thus, in certain sections of the 1998 EVS (Income and Expenditure Survey), the legislator made percentage deductions for goods and services not relevant to standard benefits (furs and bespoke clothing; camping furniture and works of art; fax machines; sports boats and gliders; tax advisor fees) without a reliable data basis on which the legislator could have assumed that the reference group (lowest quintile of households stratified according to their net income) had actually made such expenditures (Federal Constitutional Court, ibid., para. 175).
The deductions made in Department 04 for the expenditure item electricity and in Department 07 for the expenditure item and accessories for private vehicles are also not adequately justified, because although a reduction appears justifiable in principle, its amount is not empirically substantiated (BVerfG, ibid., para. 177 ff.).
Moreover, basing the calculation on the development of the current pension value constitutes an inappropriate change of benchmark. While the statistical method of calculation according to Section 28 Paragraph 3 Sentence 2 of the German Social Code, Book XII (SGB XII aF), is based on net income, consumer behavior, and the cost of living, an adjustment based on the current pension value relies on factors such as the development of gross wages and salaries, the contribution rate to the general pension insurance scheme, and a sustainability factor (Federal Constitutional Court, loc. cit., para. 184).
Measured against these specifications, the new regulations introduced by the law on the determination of standard needs and the amendment of the Second and Twelfth Books of the Social Code are not objectionable under constitutional law.
The law on determining standard needs and amending the German Social Code, Book II (SGB II) and Book XII (SGB XII), first defines the necessary subsistence level for guaranteeing the minimum subsistence allowance (§ 27a para. 1 SGB XII nF). The total necessary subsistence level constitutes the monthly standard need. This is divided into standard need levels, which, for adults, take into account the number of people in the household and whether they manage a household (§ 27a para. 2 sentences 1 and 2 SGB XII nF).
Monthly standard rates are to be granted to cover the standard needs, which result from six different standard needs levels in the annex to Section 28 of the German Social Code, Book XII (Section 27a, Paragraph 3, Sentence 1 of the German Social Code, Book XII, new version).
The procedure required for determining standard benefit rates was established by the legislature in the Act on the Determination of Standard Benefit Rates pursuant to Section 28 of Book Twelve of the Social Code (Standard Benefit Rate Determination Act – RBEG). According to this act, the standard benefit rates were determined based on special analyses of the 2008 Income and Expenditure Survey (Section 1 RBEG). This determination was based on the consumption expenditures of households in which one adult lives alone (single-person households, Section 2 No. 1 RBEG) and of households in which couples live with one child (family households, Section 2 No. 2 RBEG).
Of these households, households in which eligible persons live who received social benefits listed in Section 3 Paragraph 1 RBEG during the survey period are not to be considered as reference households.
The definition of reference households according to Section 2 of the RBEG (Standard Benefits Act) is also based on the single-person and family households of the 2008 income and expenditure survey, stratified according to their net income. After excluding households not to be considered according to Section 3 Paragraph 1, the reference households used to determine standard benefit rates are the bottom 15% of single-person households and the bottom 20% of family households (Section 4 Sentences 1 and 2 RBEG).
Initially, the legislature employed a transparent and appropriate procedure for calculating standard benefit rates, one suitable for determining the benefits necessary to secure a dignified minimum standard of living according to actual needs. It based its calculations on the actual consumption expenditures of the lower income brackets, as demonstrated by the 2008 Income and Expenditure Survey (EVS), which empirically reflects the population's consumption patterns and fundamentally opted for the statistical model (LSG Baden-Württemberg, Judgment of June 10, 2011, L 12 AS 1077/11 = juris, para. 29).
The selection of the reference group of single-person households (§ 2 No. 1 RBEG) appears suitable and appropriate. The reference to the special evaluation of the 2008 EVS (Income and Expenditure Survey) further ensures that the calculation of needs is based on reliable figures. Moreover, by taking into account the standard-needs-relevant consumption expenditures of single-person households mentioned in § 5 RBEG and the standard-needs-relevant consumption expenditures of family households mentioned in § 6 RBEG, it is ensured that the reductions criticized by the Federal Constitutional Court without an empirical basis are avoided (for further details, see also the judgment of the Higher Social Court of Baden-Württemberg of June 10, 2011, L 12 AS 1077/11 = juris, para. 32 et seq.).
At the same time, the legislator has thereby fulfilled its obligation to disclose the methods and calculation steps used. Furthermore, the legislator has ensured through the new legal regulations that deviations from the statistical model and inappropriate changes in the scale of calculation are prevented. This is because the updating of needs assessments is now based exclusively on the level and development of net income, consumer behavior, and the cost of living (§§ 28 para. 2 sentences 1 and 2, 28a para. 2 sentence 1 SGB XII).
Contrary to the plaintiff's view, the legislature has also sufficiently substantiated the savings used as the basis for standard benefit level 3. However, the plaintiff is correct in asserting that the needs underlying standard benefit levels 2 and 3, amounting to 90% and 80% respectively of standard benefit level 1, were not determined by a special evaluation of the 2008 Income and Expenditure Survey (EVS 2008) (as also expressly stated in the explanatory memorandum to the draft law on the determination of standard benefit levels and the amendment of the Second and Twelfth Books of the Social Code, BT-Drs. 17/3404, p. 130).
However, the legislator has provided detailed reasons why no special evaluations of the EVS 2008 were commissioned for the determination of standard benefit level 2 and the derived need for standard benefit level 3 (see the explanatory memorandum in the draft law on the determination of standard benefit levels and the amendment of the Second and Twelfth Books of the Social Code, BT-Drs. 17/3404, pp. 43 et seq.).
He further explained in detail that 90% of the standard benefit rate for level 2 should be applied because two adults live in one household and manage their finances together, thus sharing household costs (especially due to the shared use of appliances such as televisions, computers, refrigerators, or stoves). Specifically, he stated the following:
"A single adult or single parent must finance all household expenses, including food and clothing, on their own. This is addressed by the standard benefit level 1, which corresponds to the basic standard rate under current law. According to the draft legislation, standard benefit level 1 amounts to €364 per month and is calculated based on the standard-benefit-relevant consumer expenditures of single-person households. In households with multiple adults, a portion of the consumer expenditures necessary to guarantee a dignified minimum standard of living is allocated equally to each adult, regardless of their number in the household.".
This applies particularly to food and clothing. Due to a lack of statistical data, potential savings from joint shopping in multi-person households are not considered in these calculations. However, there are also consumption expenditures associated with running a household that are only disproportionately dependent on the number of people living in the household (household-related consumption expenditures). This applies not only to electricity and water costs, but also to the furnishings of the home. For example, a dignified minimum standard of living does not require that each person in a multi-person household have their own large electrical appliances such as a television, computer, refrigerator, or stove. The same applies to communication equipment with a flat rate for each adult.
The net additional needs of a household resulting from the addition of a second adult must therefore be lower than the needs of a single person.
Therefore, for an additional adult in the household who is not in a romantic relationship with another person in that household, the regulations for couples and the standard needs assessment for single-person households mean that this person cannot be considered a single person for social assistance purposes. Instead, the needs of this adult must be considered within the context of the household, which is why any resulting relative savings must be taken into account.
Since the additional needs of a partner in a household are lower than those of a single person, it can be assumed that this also applies to the needs of another adult in a household. The prerequisite is that the additional adult shares the existing furnishings and equipment of the apartment to the greatest extent possible with the other persons in the household and does not contribute to the costs incurred for purchase, maintenance, etc., or only contributes a very small share overall.
As a result, the remaining adult(s) in the household bear the vast majority of the household expenses. This situation arises, for example, when an adult does not actively participate in managing the household. This applies, for instance, to a subtenant whose contribution to the usage costs of household furnishings is typically made as a lump sum through the rent. In this case, such indirect cost sharing, provided the reasonable rent is not exceeded, is covered as part of the accommodation costs.
Another scenario involves parents or a parent who manages the household, when an adult child lives in the parental home, or when an adult who manages the household – possibly with their partner – takes a parent into their household. In both of these cases, if the child or parent is eligible for benefits under the German Social Code, Book XII (SGB XII), it can generally be assumed that they are entitled to basic income support for the elderly and those with reduced earning capacity (Chapter Four of the SGB XII).
The entitlement to benefits for the aforementioned persons who live in the household of other persons exists only because the maintenance presumption applicable in the assistance for subsistence (Third Chapter SGB XII) is not applicable.
This states that a person is not entitled to subsistence assistance if they live in a dwelling with other people and it can be assumed, based on the economic capacity of the other persons, that these people will provide for the subsistence of the person living with them.
Consequently, only the inapplicability of the maintenance presumption leads to an entitlement to benefits under the German Social Code, Book XII (SGB XII). The legislator intended this to enable persons who have been permanently and totally incapacitated for work since birth and early childhood to have an independent entitlement to a minimum income.
In these cases, the shared responsibility between parents and adult children was thus largely abolished. However, the introduction of basic income support for the elderly and those with reduced earning capacity was not intended to grant these persons living in the same household an entitlement as single persons (at the standard rate) or couples (at the later-introduced partner rate), but rather an entitlement equal to the standard rate share of an adult household member (80 percent of the standard rate).
The assignment of additional adults in the household to standard benefit level 3 is based on a categorization of circumstances permitted by the legislator for reasons of administrative practicality. However, social assistance law also stipulates the principle that benefits must be tailored to the specific circumstances of each individual case (§ 9 para. 1 SGB XII).
This means, specifically, that the responsible social welfare agency must take into account the particular circumstances of each individual case when determining benefits. In order to reflect the actual conditions in a household, a deviating standard rate setting is also possible in the course of exercising discretion, pursuant to Section 27a Paragraph 4 Sentence 1 of the German Social Code, Book XII (SGB XII), as amended by the draft legislation (see report of the Committee on Labour and Social Affairs, BT-Drs. 17/4095, p. 40).
The Federal Constitutional Court not only expressly approved this consideration, but even deemed an equal distribution of the reduced equal needs to be fairer than the household head principle underlying the previous social assistance law. In detail, it stated the following:
"The legislature was entitled to assume that joint management of finances would result in savings and that, therefore, two cohabiting partners have a minimum financial need that is less than twice that of a single person managing their finances alone (cf. BVerfGK 8, 338, 342). Since, due to cohabitation, it can be assumed that both partners manage their finances 'from a common pool,' it is not objectionable that the legislature sets an equal level of need for both partners. An equal division of the reduced shared need, unlike the household head principle previously practiced in social assistance law, complies with Article 3 Paragraph 2 of the Basic Law" (BVerfG, ibid., para. 154).
However, if, within the framework of standard benefit level 2, a total of 180% of standard benefit level 1 (2 x standard benefit level 2, each amounting to 90% of standard benefit level 1) is to be applied for two adults living in the same household and sharing expenses, then, following this line of reasoning, it is not objectionable that 80% of standard benefit level 1 is applied for a person who does not (co-)maintain their own household but merely lives in the household of others. This is because the household-related costs are already covered by these other persons in this case (see the explanatory memorandum to the draft law on the determination of standard benefit levels and the amendment of the Second and Twelfth Books of the Social Code, BT-Drs. 17/3404, p. 130). The legislator has further specified this reasoning and stated the following:
"The definition of standard benefit level 3 is specified in such a way that it applies to adults who do not have their own household because they live in the household of other persons and • are neither spouses or life partners of other adults living in the household, • nor live with them in a marriage-like or life-partnership-like community.".
Therefore, neither standard benefit level 1 nor standard benefit level 2 applies to these benefit recipients. The difference between standard benefit level 3 and standard benefit level 2 lies in the fact that standard benefit level 2 only applies to couples where it can be assumed that they will share the expenses. Consequently, the standard benefit is divided equally between both partners.
Standard benefit level 3, on the other hand, covers situations where there is no shared responsibility for expenses. Therefore, the existing standard benefit rate of 80 percent for a household member at standard benefit level 3 will be retained” (Report of the Committee on Labour and Social Affairs, BT-Drs. 17/4095, p. 40).
In the Chamber's view, the legislature has thus chosen a justifiable procedure and transparently presented the considerations and methods underlying the calculations. The Chamber finds no cause for concern in the fact that it did not conduct a separate evaluation of the 2008 Income and Expenditure Survey (EVS) with regard to the cases falling under standard benefit level 3.
Because he provided a coherent and comprehensible justification for the different levels of need for persons in standard benefit level 2 and persons in standard benefit level 3, and explained why, in situations such as the present one, where a permanently fully incapacitated child lives in the parents' household, there is only a need amounting to 80% of standard benefit level 1 (similarly, in effect, LSG Baden-Württemberg, judgment of 10.06.2011, L 12 AS 1077/11; LSG Lower Saxony-Bremen, decision of 24.10.2011, L 8 SO 275/11 B ER).
The court also finds no violation of the general principle of equality, Article 3 Paragraph 1 of the Basic Law (GG). In particular, it raises no constitutional concerns that, under the benefit regime of the German Social Code, Book II (SGB II), household members over the age of 25 form their own benefit unit and can thus receive the full standard benefit rate, while this is not possible for fully incapacitated benefit recipients under the benefit regime of the German Social Code, Book XII (SGB XII).
Article 3, paragraph 1 of the Basic Law does not imply a requirement of complete equality. The principle of equality merely prohibits treating one group of addressees of a legal norm differently from another group of addressees of a legal norm, even if there are no differences between the two groups of such a nature and weight as to justify the unequal treatment (established case law of the Federal Constitutional Court, see, for example, BVerfGE 71, 39 (58 f.); BVerfGE 120, 125, 144; BVerfGE 124, 199, 219 f.).
If one assumes that people over 25 years of age in need of assistance can form a benefit unit regardless of household affiliation and thus receive the full standard rate (standard benefit level 1, currently amounting to €364 per month), while this is denied to the plaintiff and thus constitutes unequal treatment, then this is constitutionally justified.
There are significant differences between the group of people receiving assistance under the benefits scheme of the German Social Code, Book XII (SGB XII), and those receiving assistance under the benefits scheme of the German Social Code, Book II (SGB II). The benefits scheme of SGB II is aimed at a group of people who are generally capable of working but only require temporary support through tax-funded social benefits (see report of the Committee on Labor and Social Affairs, Bundestag printed matter 17/4095, p. 27).
Furthermore, the ability to work (§ 8 para. 1 SGB II) and the resulting decision in favor of the benefits scheme of SGB II entail numerous duties and obligations for the benefit recipient, the (culpable) violation of which can result in serious sanctions (potentially even the denial of benefits).
Examples include the general principle of demanding performance, as laid down in Section 2 of the German Social Code, Book II (SGB II), and the principle, laid down in Section 10, paragraphs 1 and 2 of the SGB II, that any work is prima facie reasonable for benefit recipients. Also noteworthy is the comprehensive list of obligations laid down in Sections 31 and 32 of the SGB II, violations of which result in mandatory sanctions according to Sections 31a and 32 of the SGB II.
These obligations require a higher degree of personal responsibility and economic flexibility from the benefit recipient, which is why the recognition of economic independence through a higher standard rate seems justified (Report of the Committee on Labour and Social Affairs, BT-Drs. 17/4095, p. 27).
In contrast, recipients of SGB XII benefits who are permanently unable to work are largely left alone. They are not subject to a constant principle of demands that more or less force them to take up employment, nor are they subject to sanctions if the failure of such efforts is their fault.
Consequently, he does not require economic independence to the same extent as is granted to recipients of SGB II benefits who are over 25 years old.
As a result, the different design of the two benefit systems under SGB II and SGB XII is based on an objective reason. There is no violation of the general principle of equality (see also LSG Lower Saxony-Bremen, decision of 24 October 2011, L 8 SO 275/11 B ER).
Note by Willi 2: Lower Saxony-Bremen State Social Court, decision of October 24, 2011, – L 8 SO 275/11 B ER –
If a 44-year-old recipient of basic income support for the elderly and those with reduced earning capacity lives in a household with his mother who is not entitled to benefits, he is only entitled to a standard rate of EUR 291.00 according to standard benefit level 3.
There is no indication that the standard benefit rates under the Standard Benefit Determination Act are incompatible with the constitution. Firstly, the statistical model underlying the Standard Benefit Determination Act, namely the needs assessment based on special analyses conducted by the Federal Statistical Office using its 2008 Income and Expenditure Survey (EVS), represents a justifiable method for realistically determining the subsistence level.
On the other hand, any clarification of constitutional questions must be reserved for a main proceeding (cf. LSG North Rhine-Westphalia, decision of 18 April 2011 L 20 SO 133/11 B ER, there para. 15ff).
4.2 – Social Court Aachen, Judgment of 07.03.2012, – S 20 SO 151/11 –
Nursing home residents can also deduct their liability insurance premiums from their income.
Liability insurance constitutes a social welfare need within the framework of assistance for care in inpatient facilities.
According to Section 82 Paragraph 2 No. 3 of the German Social Code, Book XII (SGB XII), contributions to private insurance policies are deductible from the income required to cover necessary living expenses, provided they are reasonable in both amount and purpose. Whether a contribution to private liability insurance is reasonable in both amount and purpose and deductible from income depends on whether this insurance constitutes a precautionary measure that, while not legally mandated, appears advisable to a prudent citizen who does not have an excessive need for security (Higher Social Court of North Rhine-Westphalia, Judgment of October 30, 2008 – L 9 SO 12/06; Wahrendorf in: Grube/Wahrendorf, SGB XII Commentary, 3rd edition 2010, Section 82 SGB XII, marginal note 76). Contributions are considered reasonable for insurance policies that are widely common among the population and that sensibly cover a risk whose occurrence would place an extraordinary burden on the individual's standard of living. The decisive factor is whether a citizen living in modest circumstances, but not in need of social assistance, would have considered taking out liability insurance sensible in a comparable situation (LSG, loc. cit., citing BVerwG, judgment of May 28, 2003 – 5 C 8/02). Even someone living in tight financial circumstances with an income just above the social assistance threshold would, after weighing the insured risks against the need to save, take out liability insurance. This is because private liability insurance reasonably covers a risk whose occurrence would place an extraordinary burden on one's future standard of living (LSG NRW, loc. cit., with further references).
These principles, already established by the adjudicating chamber in its judgment of 09.05.2006 (S 20 SO 27/06) and by the LSG NRW in its confirming judgment of 30.10.2008 (L 9 SO 12/06), apply not only to people in need of assistance who live in private households, but also to nursing home residents like the plaintiff.
Finally, the defendant's concerns that the deduction of liability insurance contributions for benefit recipients without income is excluded do not preclude the application of Section 82 Paragraph 2 No. 3 of the German Social Code, Book XII (SGB XII) to benefit recipients with income – such as the plaintiff.
Even if, as the defendant suspects, this were the case, that persons with their own income would be in a better position under liability law than persons without income, this does not preclude the application of the relevant provision of Section 82 Paragraph 2 Number 3 of the German Social Code, Book XII (SGB XII), since this is what the legislator intended. The fact that this provision does not apply to persons without income cannot lead to its non-application to persons with income.
Furthermore, it would be conceivable that persons without their own income could claim contributions for private liability insurance as a further social assistance need not covered by the standard rate pursuant to Section 27a Paragraph 4 Sentence 1 of the German Social Code, Book XII (SGB XII).
5. Recipients of Hartz IV benefits are forced to undergo psychological examinations under threat of benefit suspensions.
Following several inquiries from Member of Parliament Katja Kipping, the Federal Government admitted in its answer to a minor interpellation (BT-Drs. 17/8846) that recipients of unemployment benefits or Hartz IV benefits are subjected to medical or psychological examinations under threat of suspension periods or sanctions.
"This attack on the right to self-determination of those affected is unacceptable. The forced psychiatric treatment of people is generally only known from dictatorial systems. That should be enough to deter the Federal Employment Agency and job centers from subjecting the unemployed and people with low incomes to medical and psychological services under threat of cuts to their social welfare benefits.".
“The waiting periods for unemployment benefits and sanctions for basic income support must be abolished immediately,” explains Katja Kipping, social policy spokesperson for the Left Party parliamentary group.
Note by Willi 2: Hessian State Social Court, decision of 22.06.2011, – L 7 AS 700/10 B ER –
The complete denial of benefits under Section 66 of the German Social Code, Book I (SGB I), is not covered by the exhaustive list of cases regarding benefit denials in Section 39 No. 1 of the German Social Code, Book II (SGB II), according to the clear wording of the provision (Saarland Higher Social Court, judgment of May 2, 2011, L 9 AS 9/11 B ER; Baden-Württemberg Higher Social Court, judgment of April 8, 2010, L 7 AS 304/10 ER-B; Groth in GK-SGB II, Section 39, marginal note 25; Hengelhaupt in Hauck/Noftz, SGB II, Section 39, marginal note 75).
sozialrechtsexperte.blogspot.com
6. Note on: BSG 14th Senate, Judgment of 13.04.2011 – B 14 AS 101/10 R –
Author: Dr. Thomas Harks, Judge at the Social Court, Source: jurisPR-SozR 5/2012 Note 1
Assignment of a one-euro job as an administrative act
Guidelines (from juris)
1. If no specific details regarding the content of a work opportunity have been provided in an integration agreement, the necessary stipulations will then be made by a unilateral regulation of the basic income support provider as an administrative act.
2. For a public-law claim for reimbursement, the examination of the legal basis for the work performed depends not only on the existence of an integration agreement, but also on the regulations in this allocation notice.
A. Problem Statement:
Work opportunities with additional expense allowances pursuant to Section 16d Sentence 2 of the German Social Code, Book II (so-called one-euro jobs) take place within a public-law legal relationship. For a long time, there was disagreement in case law and legal literature as to how such a legal relationship arises. The question is of considerable practical importance because if there is no effective legal basis for the work performed by the one-euro job holder, they may, under certain circumstances, assert a public-law claim for reimbursement. The Federal Social Court (BSG) has now addressed this issue.
Willi 2's note: The general public-law claim for reimbursement
A treatise by Judit Neumann, Kassel; the author is a judge at the Social Court of Halle and currently a research assistant at the Federal Social Court
Current Social Law, Journal for Social Counseling, – Nomos – Issue 1/2012
www.sozialrecht-aktuell.nomos.de (pdf)
Author of the legal case ticker: Willi 2 from Tacheles
Source: Tacheles legal case law ticker, www.tacheles-sozialhilfe.de
Part 1 of the Tacheles case law ticker for week 11/2012 can be found here.
