Sullivan v. State (2009)

In Sullivan v. State, 407 Md. 493, 502-03, 966 A.2d 919, 924 (2009), the Court held that one who never had a license cannot be convicted of driving on a revoked license because one who has no license has no privilege to drive. In that case, Sullivan's license was revoked and suspended by the Motor Vehicle Administration ("MVA"), even though he never had a driver's license. He was convicted of driving on a revoked license, among other charges. The Court reversed, and the Court of Appeals affirmed. The Court held that one who does not hold a valid driver's license has no "privilege to drive," a necessary condition of the statutes criminalizing driving while suspended and revoked. Sullivan, 407 Md. at 502-03, 966 A.2d at 924. Because Sullivan never had a license, the Court held that he had no privilege to drive, and hence, no license for the MVA to revoke. Id.