Sawyer v. State

Appellant was convicted of a third-degree felony, driving after his license had been permanently revoked, which violates section 322.341, Florida Statutes (2000). He argues that this statute is unconstitutional based on Department of Highway Safety and Motor Vehicles v. Critchfield, 805 So. 2d 1034 (Fla. 5th DCA 2002), in which the fifth district held this statute unconstitutional because it was part of Chapter 98-233, Laws of Florida, which violates the single subject rule. We respectfully disagree with Critchfield and affirm. Section 322.341 became effective July 1, 1998 by virtue of section 8 of Chapter 98-233, Laws of Florida. It provides: