## Facts

- William Thomas Rice, Jr. was charged with traffic offenses including driving while his license was suspended under Md. Code, Transp. § 16-303(c).
- After a DUI conviction, the Motor Vehicle Administration (MVA) initiated an administrative suspension process and sent Rice notice that his license would be suspended unless he requested a hearing.
- The MVA sent the notice by certified mail to Rice’s address on file; someone at his residence (identified in the record as his wife) signed for the letter.
- Rice did not request a hearing or otherwise respond, and the MVA suspended his license effective a specified date.
- On September 24, 1999, a police officer observed a car speeding, running a stop sign, making a U-turn, and speeding back; the driver pulled into Rice’s driveway and ran into the house.
- The officer, familiar with Rice and his wife at that address, went to the door, saw Rice inside, and asked for license and registration; Rice twice refused, and his wife provided the documents.
- At trial, Rice testified he did not know his license was suspended and that his wife did not tell him about the certified letter.
- In a bench trial, Rice was convicted of driving while suspended and other traffic offenses; he appealed only the driving-while-suspended conviction, challenging proof of knowledge.

## Issues

1. Whether the evidence was sufficient to prove the mens rea element of Md. Code, Transp. § 16-303(c), specifically that Rice knew (or could legally be treated as knowing) his license was suspended.

## Decision

- The Court of Special Appeals of Maryland affirmed the conviction.
- The court held the State was not required to prove Rice’s actual, subjective knowledge that he read the suspension notice.
- Evidence that the MVA sent notice by certified mail to Rice’s address on file and that it was signed for at his household permitted the fact-finder to infer knowledge or constructive knowledge of the suspension.
- Viewing the evidence in the light most favorable to the State, a rational trier of fact could find the knowledge element beyond a reasonable doubt.

## Legal Principles

- Driving while license suspended under Md. Code, Transp. § 16-303(c) includes a knowledge component, but knowledge may be established through circumstantial evidence.
- Proof that the MVA followed statutory notice procedures—certified mailing to the licensee’s last known address and documented receipt at that address—supports an inference that the licensee had sufficient notice of the suspension.
- A defendant cannot avoid liability merely by asserting he did not personally open or read a properly delivered official notice, including where another household member received the certified mail.
- On appellate review for sufficiency, the question is whether any rational fact-finder could find the elements of the offense beyond a reasonable doubt on the evidence presented, viewed most favorably to the State.

## Conclusion

Because the MVA’s certified notice was mailed to Rice’s address on file and received at his home, the trial court could infer the required knowledge for § 16-303(c); the evidence was therefore sufficient to sustain the driving-while-suspended conviction.


Rice v. State, 766 A.2d 663 (Md. Ct. Spec. App. 2001)