State of Florida, Petitioner v. Daryl Miller, Respondent

Summary

The Court affirmed the Third District Court of Appeal, holding that a revoked Florida driver’s license is a required element of a conviction under §322.34(5); therefore a person who never possessed a license cannot be charged under that statute. The Court applied a de novo plain‑meaning analysis and rejected the State’s broader interpretation of “driver license.” Justice CANADY dissented, arguing the case was moot and the Court should not issue an advisory opinion.