Anderson v. State, 87 So. 3d 774

Anderson pled no contest to burglary of a dwelling, grand theft, and falsification; sentenced to five years with suspension conditioned on two years' community control and probation, plus restitution.
An arrest warrant issued for alleged probation violation due to unpaid restitution; DHSMV had suspended Anderson's license for failure to pay restitution.
A victim reported seeing Anderson drive with a suspended license; probation officer confirmed the license suspension via driving record.
Anderson was charged with driving with a suspended license under 322.34; restitution paid after arrest and license reinstated, but probation violation proceedings continued.
Trial court held mailing notice of suspension satisfied knowledge; Fifth District affirmed, analyzing sections 322.34 and 322.251(1) and their interplay.
Court held the knowledge requirement is satisfied when notice is received, and mailing to the correct address, with receipt shown by testimony, suffices; Brown and Haygood disapproved.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Knowledge by mailed notice under 322.251(1) and 322.34(2)?	Anderson argues actual receipt required; presumption not applicable.	Brown/Haygood require actual receipt when presumption not invoked.	Knowledge satisfied by mailing to correct address with receipt testimony.
Effect of Brown and Haygood conflict?	Brown/Haygood conflict with present interpretation should control.	Brown/Haygood conflict not controlling here due to statutory text.	Disapprove Brown and Haygood to the extent conflicting; affirm the decision.

Fields v. State, 731 So.2d 753 (Fla.5th DCA 1999) (notice by mail satisfies 322.251(1) and knowledge under 322.34(2) (pre-2000 version))
Brown v. State, 764 So.2d 741 (Fla.4th DCA 2000) (presumption barred; requires actual notice for knowledge when presumption not applicable)
Haygood v. State, 17 So.3d 894 (Fla.1st DCA 2009) (adopts Brown's reasoning on knowledge without presumption)