## Facts

- Thomas P. Ridgway, age 19, had no criminal record, was employed, and had no reported substance-abuse or psychological issues.
- Ridgway drove a trash truck that struck and killed a 16-year-old boy; alcohol or drugs were not involved.
- Ridgway claimed brake failure, but an examination did not reveal defective brakes.
- Ridgway was indicted for death by auto under N.J.S.A. 2C:11-5 and applied for admission to New Jersey’s Pretrial Intervention (PTI) program.
- The PTI director denied PTI, citing the death of the victim, Ridgway’s prior accidents/traffic history, his not-guilty plea and brake-failure claim, the victim’s family’s opposition, and generalized deterrence and prosecutorial-need statements.
- The prosecutor adopted substantially the same rationale and also characterized Ridgway’s driving abstract as suggesting a continuing pattern of anti-social behavior.
- After an earlier remand directing the State to evaluate Ridgway as an individual, the PTI director and prosecutor again denied PTI with essentially the same reasons.
- Ridgway pursued a second appeal to the Law Division challenging the renewed denial.

## Issues

1. Whether the PTI director’s and prosecutor’s refusal to admit Ridgway to PTI constituted a “patent and gross abuse of discretion” requiring judicial reversal.

## Decision

- The court reversed the PTI denial, finding a patent and gross abuse of discretion.
- The court concluded the State’s analysis remained non-individualized despite the prior remand.
- The court determined that reliance on offense seriousness and victim-family opposition was treated as near-dispositive and expressed in conclusory terms.
- The court rejected the State’s use of Ridgway’s insistence on a brake-failure defense and not-guilty plea as a basis to deny PTI.
- The court found the State failed to connect its generalized deterrence and “need to prosecute” assertions to PTI criteria as applied to Ridgway’s circumstances.
- The court ordered relief consistent with reversal of the denial, effectively requiring PTI admission on this record.

## Legal Principles

- Judicial review of PTI rejection is highly deferential; reversal requires a “patent and gross abuse of discretion.”
- A patent and gross abuse of discretion may be shown where PTI rejection is based on irrelevant or inappropriate factors, fails to consider relevant factors, or reflects a clear error in judgment inconsistent with PTI goals.
- PTI decisions must evaluate the defendant as an individual, including background, character, and prospects, rather than focusing almost exclusively on the nature of the charged offense.
- Offense seriousness and victim opposition may be considered but cannot control the decision or substitute for an individualized assessment grounded in PTI criteria.
- A defendant’s refusal to admit guilt or decision to maintain a defense cannot, by itself, justify PTI rejection.
- The State must provide reasons that are specific and tied to PTI purposes and criteria, not generalized statements about deterrence or prosecutorial preference.

## Conclusion

The court held that the renewed denial of PTI was a patent and gross abuse of discretion because the State relied on conclusory and, in part, improper considerations while failing to conduct the individualized assessment required by PTI standards, warranting reversal and relief directing PTI admission on the established record.


State v. Ridgway, 504 A.2d 1241 (N.J. Super. Ct. Law Div. 1985)