State v. Vahl

Patricia Vahl was convicted of driving while adjudged an habitual traffic offender. She contends her conviction is invalid because, although notice of revocation was sent by certified mail, it was returned unclaimed. The Superior Court held that notice by certified mail satisfied the habitual traffic offender statute.

Facts

The Department of Licensing sent Vahl notice by certified mail that she was an habitual offender and that her license would be revoked for 5 years as of July 15, 1984. An habitual traffic offender is anyone who accumulates three or more specified convictions within a 5-year…