This was my exact argument.
The judge did not seem to think that Leach was relevant because it was a criminal complaint and he alluded that it did not apply to the civil offense of infraction. But both courts are of Limited Jurisdiction.From State v Leach: "We affirm the Court of Appeals and uphold superior court dismissal of Respondent Duncan Leach's public indecency conviction. The Superior Court and Court of Appeals properly based their decisions on Holt which requires that a criminal complaint allege all statutory elements of the offense charged."

