Williams v. State

At defendant’s trial on felony driving while license suspended (DWLS) the state adduced evidence of two prior convictions of DWLS. One of the two convictions, however, in 1995 did not satisfy our decision in Badger v. State, 798 So.2d 890 (Fla. 4th DCA 2001), because the statute then did not require the element of knowledge. The state argued that the trial judge could accept the DMV driving record as sufficient proof that defendant had another conviction in 1998. The trial court later found defendant guilty of felony DWLS, saying that the evidence established two post 1997 convictions. We…