Wheeler v. Appellate Division of Super. Ct.

Summary

The court held that a trial court exercising discretion to dismiss criminal charges in furtherance of justice may consider a defendant's reduced culpability, including lack of knowledge, even when the charged offenses impose strict liability. That consideration was particularly appropriate because the municipal scheme covered a broad range of culpability and contemplated noncriminal sanctions for some violators. The court also held that the trial court sufficiently acted on its own motion and that any evidentiary error concerning Wheeler's lack of knowledge was harmless, so the dismissal should stand.