Mitchell v. Maryland Motor Vehicle Administration

John T. Mitchell applied to the Maryland Motor Vehicle Administration (“MVA”) for vanity plates bearing the letters MIERDA. The application was granted. Two years later, the MVA received a complaint from a member of the public about Mitchell’s vanity plates. It investigated and determined that “mierda” is the Spanish word for “shit.” Pursuant to a State regulation giving the MVA discretion to deny or rescind vanity plates that contain profanities, epithets, or obscenities, the MVA rescinded Mitchell’s vanity plates.

Mitchell challenged the MVA’s action in a contested case hearing before an…