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.
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.
Challenging F.S. 320.061
Ticket Toro has filed a federal declaratory relief action in the U.S. District Court for the Southern District of Florida and a motion to dismiss on constitutional grounds in Miami-Dade County Court. Both actions argue F.S. 320.061 is unconstitutionally vague under the Due Process Clause because it fails to provide measurable standards for criminal liability.
Federal complaint filed: seeks statewide injunction and expungement of all citations under F.S. 320.061
State court motion: argues statute is void ab initio, seeks certification to the Third District Court of Appeal
422 criminal citations in Miami-Dade alone in under 4 months — enforcement data from our interactive map cited in court filings
Active Court Proceedings
Active Litigation
Declaratory Relief Action
Case 1:26-cv-21355-JAL · U.S. District Court, S.D. Fla. · Filed Feb 27, 2026
Castilla Rodriguez v. Miami-Dade County et al. — Seeks a declaration that F.S. 320.061 is unconstitutionally vague, a statewide injunction against enforcement, and expungement of all citations issued under the statute.
Download Filing (PDF)Motion to Dismiss for Unconstitutionality
Case AL5OJ0E · Miami-Dade County Court, Criminal Division · Filed Feb 20, 2026
State of Florida v. Yofren Perez Guerra — Argues F.S. 320.061 is void ab initio under the Due Process Clause. Cites Ticket Toro's enforcement data as evidence of irreconcilable interpretations across jurisdictions.
Download Filing (PDF)In the Press
NBC 6 South Florida
NBC6's Coverage of Ticket Toro's Constitutional Challenge
NBC6 Investigates features Ticket Toro's enforcement data and federal lawsuit challenging F.S. 320.061 across South Florida.
Telemundo 51
Cobertura de Telemundo sobre la demanda de Ticket Toro
Telemundo 51 Investiga presenta la demanda constitucional de Ticket Toro contra la ley F.S. 320.061 en los tribunales de Florida.
Take Action
Whether you've received a tag alteration citation or want to understand the legal challenge, here's how to get involved.
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Free Ticket ScanLearn Why It's Unconstitutional
Read the full legal analysis of why F.S. 320.061 fails the Due Process void-for-vagueness standard.
Read MoreSee the Enforcement Data
Explore our interactive map of 800+ tag alteration citations across 52+ agencies in Miami-Dade County.
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