In State v. McCallum, 321 Md. 451, 583 A.2d 250 (1991), McCallum was charged with driving while suspended, under TA 16-303(c). McCallum was tried by a jury. His driving record, which was admitted into evidence, showed that the MVA had mailed him three suspension letters: two for failing to pay fines in district court and one for failing to appear in district court. Ultimately, the MVA suspended McCallum's license. The suspension letters were sent by ordinary mail, consistent with the applicable provision of the Transportation Article. See TA (1987) 16-206(c). TA 16-303(c) states: "A person may not drive a motor vehicle on any highway . . . while the persons's license or privilege to drive is suspended in this State." TA 27-103(a) provides, at subsections (1) and (2), that upon failure to pay a traffic fine in accordance with the court's directive, the court may so certify to the MVA and, "after giving the person 10 days advance written notice, the MVA may suspend the driving privileges or license of the person until the fine has been paid." TA 26-204(d) provides, at subsections (1) and (2), that on receipt of a notice from the district court that a person has not complied with a notice to appear in court contained in a traffic citation, the MVA shall notify the person that his "driving privileges shall be suspended unless, by the end of the 15th day after the date on which the notice is mailed, the person" pays the fine on the original charge or posts bond or a penalty deposit and requests a new trial date. If the person does neither, the MVA may suspend his driving privileges. TA 26-204(e). McCallum testified that, notwithstanding that the suspension letters had been mailed to the apartment that the MVA had on record as his address, he did not receive them because, when they were mailed, he was in jail on an unrelated charge, and was not living in the apartment. Moreover, while he was in jail, and during the time that the suspension letters were mailed, his landlord had brought eviction proceedings against him and had confiscated and destroyed all of his mail. Thus, according to McCallum, he never received the suspension letters and, at the time of his arrest for driving while suspended, did not know that his license had been suspended. McCallum asked the trial court to instruct the jury that criminal intent is an element of the crime of driving while suspended. The court declined to do so. McCallum was convicted, and appealed on the ground, inter alia, that the trial court's refusal to instruct the jury about criminal intent was in error. The Court reversed the conviction, holding that mens rea is an element of the crime of driving while suspended. McCallum v. State, 81 Md. App. 403, 567 A.2d 967 (1990). The Court of Appeals granted certiorari and affirmed the decision of this Court in a per curiam opinion. Reasoning that driving while suspended is not a "public welfare" offense in which the legislature "intended to eliminate the requirement of scienter" and create a strict liability offense, 321 Md. at 457, the Court held that "mens rea is required for the charge of driving while suspended, and the trial judge erred in failing to so instruct the jury." Id. The Court did not elaborate further. In a concurring opinion, Judge Chasanow, expressing the belief that, for the guidance of the trial court, the Court of Appeals "should . . . elaborate on the mens rea that would be necessary to convict," 321 Md. at 458, explained that the criminal intent required for the offense of driving while suspended "is 'knowledge' rather than 'intent.' Unquestionably, McCallum intended to drive. The issue is whether McCallum had 'knowledge' that his driving privileges were suspended, and thus, his mental state must be assessed." Id. Judge Chasanow further explained that knowledge in this context can be "actual knowledge," meaning "an actual awareness or an actual belief that a fact exists," or "'deliberate ignorance' or 'willful blindness,'" which is to say that a person "believes that it is probable that something is a fact, but deliberately shuts his or her eyes or avoids making reasonable inquiry with a conscious purpose to avoid learning the truth." Id. "Deliberate ignorance requires a conscious purpose to avoid enlightenment; a showing of mere negligence or mistake is not sufficient. Also, 'deliberate ignorance' is a form of knowledge, not a substitute for knowledge. Therefore, if McCallum actually believed that his driver's license was not suspended, he could not be guilty of the offense." Id. at 461. Judge Chasanow went on to describe facts that would be sufficient to support a finding of deliberate ignorance in McCallum's case: Deliberate ignorance should be established if McCallum believed it was probable that his license was suspended and if he deliberately avoided contact with the MVA to evade notice. For example, the trier of fact could find that: 1) based on his failure to pay district court fines and failure to appear in court, McCallum knew that it was probable that his license was suspended; 2) McCallum failed to fulfill his obligation to keep MVA apprised of his current address, fn or that he failed to contact MVA after learning that for several months his mail was destroyed, and 3) McCallum deliberately avoided contact with MVA to avoid receiving notice of the suspension of his driver's license. These findings should justify a conclusion that McCallum's intentional avoidance of notice of his suspension satisfied the mens rea requirement and was the equivalent of actual knowledge of his suspension. fn Md. Code (1984, 1987 Repl. Vol., 1990 Cum. Supp.), Transportation Article, 16-116 (a) requires a licensed driver to notify the MVA within thirty days of moving from the address shown on the license. 321 Md. at 461.