Smith v. State
Annotate this CaseAfter being pulled over for a routine traffic stop, Petitioner Tyrone Smith was convicted of driving without a license. Petitioner was convicted under Md. Code Ann, Transp. 16-101(a) (the statute), which contains three parts. Petitioner appealed, claiming that the State must prove all three parts of the statute as elements of the offense beyond a reasonable doubt. The Court of Appeals affirmed, holding that the State need only prove the first part of the statute to convicted a defendant of driving without a license, and that the second and third parts are affirmative defenses that must be raised by a defendant.
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