Wolfe v. Georgia Department of Driver Services, 330 Ga. App. 552

Gregory A. Wolfe appeals a Cobb County Superior Court decision affirming the Georgia Department of Driver Services’ cancellation of his Georgia driver’s license.
Illinois imposed a lifetime ban on Wolfe’s driving privilege based on a 1999 statute, but Wolfe was never an Illinois resident and never held an Illinois driver’s license.
Wolfe moved to Georgia in 1999 and obtained a Georgia driver’s license; he was DUI-convicted in Georgia in 2001.
Illinois notified the Department of the conviction and revoked Wolfe’s Illinois privilege to drive, triggering the State’s license-cancellation scheme.
The Department cancelled Wolfe’s Georgia license under OCGA § 40-5-50 after the Illinois ban, and the final agency decision was issued January 16, 2013, with the Cobb County trial court affirming on April 8, 2014.
Wolfe challenges the Department’s authority to cancel a Georgia license based on an out-of-state driving privilege that was suspended, even though Illinois never issued him a physical license.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Department may cancel a Georgia license due to an out-of-state driving privilege suspension.	Wolfe: Illinois never issued a license, so §40-5-22(c)(7) cannot apply.	Department: privilege to drive in Illinois is covered by the statute and may justify cancellation.	Yes; Department may cancel based on out-of-state privilege suspension.

Roberts v. Burgess, 279 Ga. 486 (2005) (upholds government interest in restricting licenses and considering out-of-state actions)
Aimwell v. McLendon Enterprises, Inc., 318 Ga. App. 394 (2012) (statutory construction harmonizes related provisions)
Kane v. New Jersey, 242 U.S. 160 (1916) (state power to regulate nonresidents on highways; respect for other states’ sanctions)
Lakeview Behavioral Health System, LLC v. UHS Peachford, LP, 321 Ga. App. 820 (2013) (statutory construction; interpret terms in light of whole code)