Keller v. State

Although I fully concur with Divisions 2, 3, 4 and 5, I must respectfully dissent as to Division 1.

In prosecutions under OCGA § 40-5-58, the State is required to prove that the accused was declared a habitual violator, was properly notified of such status, and operated a vehicle without having obtained a valid driver’s license.13 The majority rejects Keller’s argument that the trial court erred in admitting two documents showing that he had been properly notified.

The first document at issue is an Official Notice of Revocation, which states that Keller has been declared a habitual violator.…