1. Decisions of the Federal Social Court of 17 March 2016 on basic income support for job seekers (SGB II)
1.1 – BSG, Judgment of 17.03.2016 – B 4 AS 32/15 R
Basic income support for job seekers – Exclusion of benefits for foreigners residing for the purpose of seeking employment – EU citizens – insufficient labor market connection – less than 1 year of employment as a worker – expiry of the 6-month period – Spanish nationals
Note to the Court:
1. According to the rulings of the European Court of Justice in the "Dano" and "Alimanovic" cases, the exclusion of benefits under Book II of the German Social Code (SGB II) – even for EU citizens who have already been employed in the Federal Republic of Germany – is in accordance with European law. With regard to benefits under Book II of the German Social Code (SGB II), the plaintiff cannot invoke the principle of equal treatment under Article 1 of the European Convention on Social and Cultural Rights. This is precluded by the reservation declared by the German Federal Government on December 19, 2011, pursuant to Article 16(b) of the EFA, which is formally and materially valid.
2. Since the Federal Government has not declared any reservations regarding subsistence assistance under Book XII of the German Social Code (SGB XII), social assistance benefits must be provided on an equal basis with domestic nationals. The exclusion clause of Section 23 Paragraph 3 Sentence 1 Alternative 2 of Book XII of the German Social Code (SGB XII) therefore does not apply from the outset. This equal treatment requires that the national of a contracting state of the EFA (European Family Assistance Act) member has lawful residence in Germany, which is the case at least when the national has a right of residence for the purpose of seeking employment.
Source: juris.bundessocialgericht.de
2. Decisions of the Federal Social Court on employment promotion (SGB III)
2.1 – BSG, Judgment of 17.03.2016 – B 11 AL 4/15 R
Suspension of unemployment benefit entitlement – Holiday pay – Cross-border workers – Payment of Danish holiday pay after termination of employment in Denmark – Comparability
Guiding principle (Editor)
1. The holiday pay accumulated in Denmark is to be classified as holiday compensation within the meaning of Section 143 Paragraph 2 SGB III a. F.
2. There are no fundamental constitutional or European legal concerns regarding this result.
Source: juris.bundessocialgericht.de
3. Decisions of the State Social Courts on Basic Income Support for Job Seekers (SGB II)
3.1 – State Social Court of North Rhine-Westphalia, Judgment of 28 January 2016 – L 7 AS 948/15 – Leave to appeal is granted
Regarding the question of whether two dog liability insurance policies can be deducted from the applicant's income.
No deduction of contributions to dog liability insurance from earned income.
Principle (Editor):
1. The law does not contain a legal basis for deducting contributions to dog liability insurance. In particular, deductibility does not follow from Section 11b Paragraph 1 Sentence 1 Number 3 of the German Social Code, Book II (SGB II).
2. The applicant cannot derive the deductibility from the second alternative of Section 11b Paragraph 1 No. 3 Sentence 1 2. SGB II either.
3. Subsequently, insurance premiums that are not legally required can be considered if they are reasonable in both purpose and amount. Animal liability insurance can only be recognized if keeping the animal is necessary for professional, health, or other reasons.
4. These conditions are not met. The applicant has denied having health or professional reasons for keeping the dog. Therefore, deductibility as a necessary expense related to generating income within the meaning of Section 11b Paragraph 1 Sentence 1 No. 5 of the German Social Code, Book II (SGB II), is also excluded.
Source: socialcourtsability.de
3.2 – Lower Saxony-Bremen State Social Court, decision of 22 February 2016 – L 9 AS 1335/15 B ER
No benefits under the German Social Code Book II/Book XII for Romanian applicants in preliminary legal protection proceedings.
In principle, no social assistance is available for employable EU citizens
The Senate does not follow the jurisprudence of the Federal Social Court (BSG), according to which, for a period exceeding six months, "for reasons of the systematic nature of social assistance law and the constitutional requirements of the Federal Constitutional Court (BVerfG)," benefits for subsistence assistance must be provided in accordance with Section 23 Paragraph 1 Sentence 3 of the German Social Code, Book XII (SGB XII).
Principle (Juris)
1. Employable Union citizens who are excluded from benefits under the German Social Code, Book II (SGB II) pursuant to Section 7 Paragraph 1 Sentence 2 No. 2 SGB II are not entitled to subsistence assistance under the German Social Code, Book XII (SGB XII) (Section 21 Sentence 1, Section 23 Paragraph 3 Sentence 1 Alternative 2 SGB XII).
2. The exclusion of employable Union citizens from ongoing benefits under the German Social Code, Book II (SGB II) and Book XII (SGB XII) is not unconstitutional.
Source: socialcourtsability.de
Note:
See also: Social assistance for EU citizens excluded from basic income support (SGB II)?
The LSG Celle-Bremen has contradicted the BSG's view that EU citizens are entitled to social assistance if they are excluded from basic income support under the SGB II in two recent decisions.
Source: Press release from the Celle-Bremen Higher Social Court dated March 17, 2016: www.juris.de
Legal tip:
The following decisions reject a claim to social assistance: LSG Mainz, decision of February 11, 2016 – L 3 AS 668/15 B ER; LSG Berlin-Brandenburg, decision of January 22, 2016 – L 29 AS 20/16 B ER. Two senates of the LSG Berlin-Brandenburg, for example, affirm a claim to social assistance (LSG Berlin-Brandenburg, decision of December 21, 2015 – L 25 AS 3035/15 B ER and LSG Berlin-Brandenburg, decision of January 15, 2016 – L 28 AS 3053/15 B ER).
3.3 – Lower Saxony-Bremen State Social Court, Judgment of 26 January 2016 – L 11 AS 1076/14 – The appeal on points of law is granted due to the fundamental importance of the legal issue
The only ruling so far that has been definitively established by the highest court is that third-country nationals who enter the Federal Republic of Germany as family members of a German citizen are not excluded from benefits under the German Social Code, Book II (SGB II) during the first three months of their stay (Federal Social Court, judgment of January 30, 2013 – B 4 AS 37/12 R).
No exclusion of benefits for foreigners during the first three months of their stay in the case of family reunification with their spouse.
Principle (Juris):
Family members of a foreigner who holds a residence permit under Section 5 of Chapter Two of the German Residence Act (AufenthG) and is therefore entitled to benefits under Book II of the German Social Code (SGB II) due to the exception in Section 7 Paragraph 1 Sentence 3, are also not subject to the exclusion from benefits under Section 7 Paragraph 1 Sentence 2 of Book II of the German Social Code (SGB II) if they enter Germany on the basis of an entry visa issued for the purpose of family reunification and are subsequently granted a residence permit under Section 6 of Chapter Two of the German Residence Act (AufenthG) following a certificate of deemed residence. A different approach is not justified by the basic structure of Section 7 Paragraph 1 Sentence 2 of Book II of the German Social Code (SGB II) and also contradicts the Federal Employment Agency's professional guidelines on Section 7 of Book II of the German Social Code (SGB II).
Source: socialcourtsability.de
3.4 – Lower Saxony-Bremen State Social Court, decision of 07.03.2016 – L 15 AS 185/15 B ER
Principle (Juris)
1. The entitlement to social assistance of EU citizens who are excluded from receiving ALG II benefits by Section 7 Paragraph 1 Sentence 2 No. 2 of the German Social Code, Book II (SGB II), is limited, according to Section 23 Paragraph 3 Sentence 1 and Paragraph 1 Sentence 3 of the German Social Code, Book XII (SGB XII), to a discretionary decision by the social assistance provider that is free of error and depends on the circumstances of the individual case, even if the stay in Germany lasts more than six months.
2. Contrary to the case law of the Federal Social Court (judgment of December 3, 2015, file no. B 4 AS 44/15 R), it cannot be assumed that there is a regular obligation, commencing at the beginning of the seventh month of residence, to grant ongoing benefits in accordance with Chapter Three of the German Social Code, Book XII, by way of a reduction of discretion to zero.
Source: socialcourtsability.de
Note:
Sat: Social assistance for EU citizens excluded from basic income support (SGB II)?
The LSG Celle-Bremen has contradicted the BSG's view that EU citizens are entitled to social assistance if they are excluded from basic income support under the SGB II in two recent decisions.
Source: Press release from the Celle-Bremen Higher Social Court dated March 17, 2016: www.juris.de
3.5 – Lower Saxony-Bremen State Social Court, Decision of 15 January 2016 – L 15 AS 226/15 B ER
Matters under the German Social Code, Book II (SGB II) – Exclusion of benefits for foreigners residing for the purpose of job seeking – EU citizens – Migrant workers – Participation in general school instruction
Principle (Juris)
1. The right of residence granted to children of so-called migrant workers under Article 10 of Regulation (EU) No. 492/2011 to ensure their participation in general schooling or the completion of vocational training does not preclude the exclusion from benefits under Section 7 Paragraph 1 Sentence 2 No. 2 of the German Social Code, Book II (SGB II). It is, at most, a derivative right of a derivative right, which has no protective effect in this respect.
2. Emergency assistance benefits under the German Social Code, Book XII (SGB XII), must be claimed separately from the social welfare agency. In any case, there is no reason to join the social welfare agency as a party in preliminary legal proceedings.
Source: socialcourtsability.de
Note:
Sat: EU citizens: Exclusion from SGB II benefits even with a possible right of residence through school attendance – Press release of the LSG Celle-Bremen dated March 17, 2016: www.juris.de
Legal tip:
In its judgment of December 3, 2015 – B 4 AS 43/15 R, the Federal Social Court (BSG) takes a different legal view – no exclusion from benefits exists if a right of residence exists pursuant to Article 10 of Regulation (EU) No 492/2011 for children in education and their parents with custody; similarly: Higher Social Court of Saxony-Anhalt, decision of January 21, 2016 – L 2 AS 624/15 B ER – non-application in the case of a right of residence as a parent with custody of a child in education; Higher Social Court of North Rhine-Westphalia, decision of March 16, 2015 – L 19 AS 275/15 B ER – entitlement to basic income support benefits for a parent with custody, taking into account the right of residence as a family member of their school-age child; similarly, regarding this right of residence, decisions of the Senate of 27 January 2016 – L 19 AS 29/16 B ER – and of 20 January 2016 – L 19 AS 1824/15 B ER
3.6 – State Social Court of Saxony-Anhalt, Judgment of 08.10.2015 – L 5 AS 638/14
Guiding principle (Editor)
1. No benefit for initial furnishing of an apartment from basic income support funds if the need is already met before the application is submitted to the basic income support provider.
2. The application process under Section 37 of the German Social Code, Book II (SGB II) establishes a constitutive application requirement, with the consequence that benefits are only payable from the date of application (see Federal Social Court [BSG], judgment of August 19, 2010, B 14 AS 10/09 R). No exceptions to this are provided for by law.
3. Granting the requested benefits by way of a social security restitution claim is also not possible. An administrative procedure is only initiated upon application pursuant to Section 37 of the German Social Code, Book II (SGB II), in which both the applicant (here, the plaintiff) and the defendant, as the basic income support provider, are subject to specific obligations, which are detailed in the First Book of the German Social Code (General Part – SGB I). Any advisory obligations therefore only arise at this point (see Federal Social Court [BSG], Judgment of October 28, 2009, B 14 AS 56/08 R).
Source: socialcourtsability.de
Legal tip:
Similarly regarding the German Social Code, Book XII (SGB XII): Social Court Karlsruhe, judgment of October 4, 2013 – S 1 SO 2746/13
3.7 – State Social Court of Saxony-Anhalt, decision of 17 February 2016 – L 4 AS 345/15 B ER legally binding
Matters under the German Social Code, Book II (SGB II) (AS) – Regarding debt assumption pursuant to Section 22 Paragraph 8 of the German Social Code, Book II (SGB II)
Principle (Juris)
1. A debt assumption pursuant to Section 22 Paragraph 8 Sentence 2 of the German Social Code, Book II (SGB II) can only take place if it is objectively suitable to secure the currently occupied apartment as accommodation in the long term and permanently, the beneficiary has exhausted his reasonable self-help options and is also threatened with homelessness.
2. Homelessness within the meaning of Section 22 Paragraph 8 Sentence 2 of the German Social Code, Book II (SGB II) requires that the loss of the previously occupied dwelling is imminent, that this dwelling is cost-appropriate, and that at the same time there is no possibility of renting a suitable replacement dwelling (cf. Federal Social Court, Judgment of June 17, 2010, B 14 AS 58/09 R, juris RN 30).
3. There is no entitlement to an interim order for debt assumption pursuant to Section 22 Paragraph 8 of the German Social Code, Book II (SGB II), if the currently occupied apartment is unsuitable, in addition to energy debts, termination of the tenancy is threatened due to serious rent arrears, and suitable alternative accommodations are available on the rental market which the benefit recipient can rent.
Source: socialcourtsability.de
3.8 – State Social Court of Saxony-Anhalt, judgment of 16.12.2015 – L 2 AS 733/13 legally binding
Matters under the German Social Code, Book II (SGB II) – (AS)
Principle (Juris):
If, at the time of the revocation decision, the prerequisites for a final determination of the benefit entitlement already exist, the reimbursement of overpaid benefits is governed solely by Section 40 Paragraph 1 No. 1 of the German Social Code, Book II (SGB II) (old version) and Section 328 of the German Social Code, Book III (SGB III). Reimbursement of overpaid benefits then requires that a final decision has already been made regarding the benefit entitlement. An amendment notice pursuant to Section 48 of the German Social Code, Book X (SGB X) does not regularly contain such a final decision and cannot be reinterpreted as a notice of final determination of benefits (following the Federal Social Court's ruling of April 29, 2015 – B 14 AS 31/14 R).
Source: socialcourtsability.de
3.9 – State Social Court of Saxony-Anhalt, decision of 01.03.2016 – L 5 AS 25/16 B ER
Regarding the request to apply for early retirement (here affirmative)
Principle (Juris)
1. There are neither constitutional nor European law objections to the regulation of § 12a SGB II.
2. Whether gainful employment within the meaning of Section 4 of the Unreasonableness Ordinance is imminent must be determined based on a prognosis. Subsequent developments can neither confirm nor refute this prognosis.
3. The eligible recipient of benefits who is capable of working must be given a reasonable deadline to submit their application. The length of this deadline depends on the circumstances of the individual case and must not be less than one week. A deadline that is too short does not render the request to submit an application invalid. However, the alternative application by the basic income support provider pursuant to Section 5 Paragraph 3 Sentence 1 of the German Social Code, Book II (SGB II), would only be possible after the reasonable deadline has expired.
4. The application by the basic income support provider pursuant to Section 5 Paragraph 3 Sentence 1 of the German Social Code, Book II (SGB II) is not an administrative act.
5. If an employable person in need of assistance submits a pension application after a lawful request by the basic income support provider, he cannot withdraw this application without the provider's consent.
Source: socialcourtsability.de
4. Decisions of the social courts on basic income support for job seekers (SGB II)
4.1 – Cologne Social Court, judgment of February 2, 2016 (Case No.: S 11 AS 1756/12):
Guiding principle Dr. Manfred Hammel
1. The realizability of assets within the meaning of Section 12 Paragraph 1 SGB II must be given in legal, economic and factual terms.
2. If, according to a forecast decision to be made, the asset cannot be made usable in the foreseeable future, i.e. within an expected six months, it lacks actual usability.
3. This asset is then not to be taken into account when assessing eligibility for assistance (§ 9 SGB II).
4. This applies if neither the value of a property located abroad nor the aspect of the marketability of this property can be clarified in a reasonable manner, and the sale of the entire area can only be carried out through a compulsory dissolution of the owners' association.
5. In this case, benefits under Sections 20 et seq. of the German Social Code, Book II (SGB II) are to be provided to applicants as a grant and not as a loan in accordance with Section 42a Paragraph 1 Sentence 1 of the German Social Code, Book II (SGB II).
4.2 – SG Landshut, March 8, 2016, Ref. S 5 AS 271/15
High workload does not justify the job center's inaction in the appeal process, an article by attorney Mathias Klose, Regensburg
Source: Sozialrecht-aktuell.blogspot.de
4.3 – Aurich Social Court, Judgment of 09.01.2013 – S 15 AS 651/09
Payments from a credit line insurance as income (here denied) – payments would be made to secure home financing due to the plaintiff's incapacity for work – (§ 11 para. 3 no. 1 a SGB II in the version valid until 31.2010).
Principle (Editor):
1. Payments from a so-called credit line insurance policy are not considered income.
Section 11 Paragraph 3 No. 1a of the German Social Code, Book II (SGB II) aims to prevent the specific purpose of a benefit from being undermined by its consideration within the framework of the SGB II, insofar as the purpose may arise from a public law regulation or a private law agreement (Federal Social Court -BSG-, judgment of January 18, 2011 – B 4 AS 90/10 R; judgment of March 3, 2009 – B 4 AS 47/08 R).
2. A benefit provided on a civil law basis is considered earmarked within the meaning of this provision if, beyond the purpose of repayment, it is recognizably assigned a specific purpose. This is the case if it is objectively evident from an agreement that the benefit is to be used for a specific purpose (cf. BSG, loc. cit. and judgment of 01.06.2010 – B 4 AS 89/09 R).
3. The design of the credit line insurance makes it sufficiently clear that the insurance is primarily taken out in the interest of the bank and is intended to ensure that the loan given by the bank can be repaid even in the event of the death or incapacity of the borrower.
Source: socialcourtsability.de
4.4 – SG Oldenburg, Judgment of 20.05.2015 – S 39 AS 1567/12
Private accident insurance for children is appropriate in individual cases
Children's accident insurance may be tax-deductible from income under certain circumstances (affirmed here for both children – riding in a private sports club, participation in football games)
This is related to an article from the magazine “quer”, issue 15 2016, with reference to RA Böning, OL
"Special circumstances of an individual case may lead to such private insurance being deemed appropriate. These may include, for example, a particular risk to the young person due to an illness or disability, or another life situation that poses a particular risk (cf. Federal Social Court, judgment of May 10, 2011 – Case No.: B 4 AS 139(10 R)). Such a case exists here.".
The plaintiff, a minor, rides at a private riding club. The girl is therefore exposed to an increased risk of accidents and disability during her free time. However, leisure accidents and their consequences are not covered by statutory accident insurance. Furthermore, membership in the private riding club, which has taken out private accident insurance for its members, is so expensive that the plaintiff can hardly participate in her sport anymore.
The same applies to the sport played by the boy in question. General experience suggests that participating in football games involves a considerable risk of injury. Therefore, private accident insurance is an appropriate safeguard against this risk.
Source: www.also-zentrum.de
4.5 – SG Aurich 55th Chamber, Final Judgment of 27 March 2014 – S 55 AS 498/12
Matters under the German Social Code, Book II (SGB II) do not incur any fees for litigation proceedings
Principle (Juris):
Credit balances from amounts that a benefit recipient has paid from their standard allowance or their income exempt from being counted towards benefits during the accounting period cannot be counted towards benefits under Section 22 Paragraph 3 of the German Social Code, Book II (SGB II).
Source: socialcourtsability.de
Legal tip:
See also LSG NSB, judgment of 23.09.2015 – L 13 AS 164/14, SG Aurich, judgment of 29.04.2014 – S 55 AS 445/13, not published
4.6 – SG Dortmund, Judgment of 19.02.2016 – S 62 SO 444/14
No coherent concept for determining the need for accommodation in the Hochsauerland district
Source: www.lokalkompass.de
Full text of the decision: www.beispielklagen.de
5. Decisions of the social courts on social assistance (SGB XII)
5.1 – Berlin Social Court, Decision of December 7, 2015 (Case No.: S 92 SO 2913/15 ER)
Principle by Dr. Manfred Hammel
1. Even if the procedure for terminating the agreement pursuant to Section 75 Paragraph 3 of the German Social Code, Book XII (SGB XII) in conjunction with the framework agreement pursuant to Section 75 of the German Social Code, Book XI (SGB XI) is separately regulated in the case of an officially asserted unreliability of a (still) approved care service, the social welfare agency has the right and the duty, in addition to initiating steps to terminate its contractual obligations to the care service in question, to ensure the coverage of care needs by third parties or by informing the persons in need of care about the social welfare office's findings regarding the (lack of) reliability of a specific care service.
2. The contract termination process can take a considerable amount of time, so that the risk to those in need of care cannot be ruled out solely by issuing the necessary contract termination notice.
3. Especially in particularly justified individual cases, the social welfare provider must also be entitled to warn the recipients of assistance about a care service deemed unreliable by the official assessment, or to refuse to cover the costs of care provided by a care service considered unreliable, while simultaneously declaring the coverage of costs for other, approved care services.
4. The legitimate interests of those requiring assistance and care demand this, especially when it is no longer readily apparent to the care service itself whether it has actually provided all the necessary care services – as approved – in a given case. In such circumstances, adequate care for those requiring assistance is not guaranteed, and the care service would be solely focused on its financial gain at the expense of the general public, thereby crossing the line into criminal activity.
Note:
See also: Social Affairs Councillor does not have to go to prison
Press release no. 598/2015 of December 22, 2015: https://www.berlin.de
5.2 – Social Court Karlsruhe, decision of 17 December 2015 – S 1 SO 4053/15 ER
Social assistance – preliminary legal protection – subsistence assistance – need for assistance – substantiation – burden of proof – increased requirements for substantiation
Principle (Juris):
If an applicant for assistance has concealed from the assistance provider the acquisition of assets during the period of receiving benefits, which led to the cessation of their need for assistance, stricter requirements apply to substantiating the subsequent occurrence of renewed need for assistance. The mere assertion, without any verifiable documentation, that the assets have been completely depleted is insufficient in this respect.
Source: socialcourtsability.de
6. Decisions of the social courts on employment promotion law (SGB III)
6.1 – Social Court Dortmund, Judgment of 29 February 2016 – S 31 AL 859/12
Regarding the revocation of unemployment benefit approval due to a failure to report and an unauthorized absence from the place of residence – the absence was not previously approved – important reason – analogous application of Section 141 Paragraph 3 of the German Social Code, Book III (here the revocation was unlawful)
An important reason for failing to attend a scheduled appointment is when children – including adult children – ask their parents for help and support due to psychological distress.
Principle (Editor):
In the case of such an unlawfully refused subsequent approval of absence from the place of residence, the termination of benefits cannot be based on a lack of availability. Rather, in the case of an unlawful refusal of subsequent approval of absence from the place of residence, approval must be deemed to have been granted. The deemed subsequent approval of absence from the place of residence then, in accordance with Section 3 of the EAO (Employee Benefits Act), establishes the plaintiff's availability despite their absence.
Source: socialcourtsability.de
7. Decisions of the social courts on asylum law
7.1 – SG Berlin, decision of 19 January 2016 – S 212 AY 76/16 ER
Guiding principle Dr. Manfred Hammel
1. A tonsillectomy constitutes the treatment of an acute illness and a painful condition within the meaning of Section 4 Paragraph 1 Sentence 1 of the Asylum Seekers' Benefits Act (AsylbLG), provided that the acute sore throat complained of by the applicant cannot be treated solely with antibiotics, and the procedure must be performed urgently in order to prevent relapses, which may be life-threatening.
2. The agency responsible for implementing the Asylum Seekers' Benefits Act (AsylbLG) is obliged to cover the costs of pre-hospital and inpatient treatment of tonsillitis and to immediately issue and hand over a cost coverage certificate to the applicant.
8. Düsseldorf Administrative Court: Liability arising from a declaration of commitment even after successful conclusion of the asylum procedure
Administrative Court Düsseldorf, 22nd Chamber, Judgment of 01.03.2016 – 22 K 7814/15 – Direct appeal to the Federal Administrative Court allowed
Anyone who undertakes to cover the living expenses of a Syrian refugee until either their stay in Germany ends or the original purpose of stay is replaced by another and a new residence permit is granted for that purpose, remains liable for the costs even if the foreigner is granted a residence permit after successful completion of an asylum procedure.
The court has granted leave to appeal directly to the Federal Administrative Court against the judgment.
Case number: 22 K 7814/15
Source: www.vg-duesseldorf.nrw.de
9. SGB II: Subsequent claims for heating and so-called cold ancillary costs, an article by Herbert Masslau.
Preliminary remarks:
This article deals with the crediting procedures for subsequent claims either from landlords or so-called third-party suppliers (e.g., municipal utilities) or, in the case of home ownership, from municipal charges.
Source: www.herbertmasslau.de
10. Asylum Seekers' Benefits Act: €10 reduction from March 17, 2016
From March 17, 2016, new standard benefit rates apply under the Asylum Seekers' Benefits Act (basic benefits): The monthly "necessary personal needs" (the so-called "pocket money") will be reduced by ten euros in standard benefit level 1 and will amount to only 135 euros instead of the previous 145 euros, the total needs thus being 354 euros instead of 364 euros.
Publication: www.alg-ratgeber.de
The 11th issue of the unemployment magazine "quer" (issue 15/March 2016) is available for download
Here: www.also-zentrum.de
Author of the legal news ticker: Willi 2 from Tacheles – alias Detlef Brock
Source: Tacheles legal case law ticker, www.tacheles-sozialhilfe.de
