Constitutional Challenge

One Statute. Sixty-Seven Interpretations.

A standard dealer license plate frame is lawful in some Florida counties and criminal in others. The same frame. The same statute. Different outcomes depending on geography. We're challenging F.S. 320.061 as unconstitutionally vague.

The Problem

When Identical Conduct Produces Opposite Legal Conclusions

A Florida driver buys a new car in Miami. The dealer installs a standard license plate frame — the same frame found on millions of Florida vehicles. It partially covers the “S” in “Sunshine State.”

She does not speed. She does not run a light. Yet for portions of her drive, she is committing a crime — or so Miami-Dade, Broward, Lake, and Escambia Counties would say. Pensacola Police have publicly declared that “nothing can be obscured on the tag,” including “Sunshine State.”

In Seminole, Volusia, Orange, St. Lucie, Duval, and Leon Counties, however, identical frames have been declared lawful as long as the alphanumeric characters and registration decal remain visible.

Cross a county line, and legal conduct becomes criminal.

The Dawson Case

In December 2025, Davie police arrested and jailed Demarquize Dawson because a decorative frame partially covered the letter “S” in “Sunshine.” The department later acknowledged the arrest was “invalid” and publicly admitted the statute's wording was “vague, unclear and appeared to be open for misinterpretation.”

The Due Process Argument

The Due Process Clause requires that criminal statutes define liability with measurable standards. When trained law enforcement agencies read the same language and reach irreconcilable interpretations, that divergence evidences the absence of any objective benchmark for criminal liability.

The Enforcement Data

Our interactive map documents the inconsistent enforcement of F.S. 320.061 across Miami-Dade County using public records data.

800+
Citations Mapped
52+
Agencies Enforcing
160+
Enforcement Days
67
County Interpretations
Constitutional Challenge

Challenging F.S. 320.061

Ticket Toro is actively challenging the constitutionality of F.S. 320.061. We argue the statute is unconstitutionally vague under the Due Process Clause because it fails to provide measurable standards for criminal liability.

1

Sixty-seven counties, irreconcilable enforcement interpretations

2

No objective benchmark for what constitutes “alteration” or “obstruction”

3

Seeking a ruling that the statute is void for vagueness

The Constitutional Argument

Challenging F.S. §320.061 as Void for Vagueness

StatuteF.S. §320.061
ArgumentVoid for Vagueness
BasisDue Process Clause
Counties AffectedAll 67
StatusActive Challenge

Court filings and updates to follow

Media Coverage

In the Press

Press Coverage Coming Soon

Media inquiries and press materials available upon request.

tech@tickettoro.ai

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