Rick Cremer did not issue legal interpretations when he worked for
the FAA.

Nor did he in this case. He merely reiterated FAA Policy. Notice
that he said "cleared through the FAA's Chief Counsel's office." ?

Unless he was lying, it is not FAA policy to violate a pilot for not
carrying charts, because there is no regulation that would support the
violation.

I do agree that you can't function IFR without charts, but I also
think the lack of a legal requirement to carry charts is important to
note here because it puts this question about "can I use downloaded
charts" into perspective. The question then becomes "is it safe?"
rather than "is it legal?"