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Traffic Stop: Failure to Display Front Plate

State v. Terrence T. Boyd, 2012 WI App 39 (recommended for publication); for Boyd: Andrea Taylor Cornwall, SPD, Milwaukee Appellate; case activity

Because Boyd’s car was registered in a state (Illinois) that issues two plates, car could be stopped for failing to display a plate on the front, in violation of § 341.15(1) (“[w]henever 2 registration plates are issued for a vehicle, one plate shall be attached to the front and one to the rear of the vehicle.”).

¶7        Now, having dispensed with Boyd’s main argument, we can get down to the business of interpreting Wis. Stat. § 341.15, titled “Display of registration plates.” As we already pointed out, § 341.15(1) states that “[w]henever 2 registration plates are issued, one plate shall be attached to the front and one to the rear of the vehicle.”  (Emphasis added).  Given the legislature’s use of the word “whenever,”[2] § 341.15(1) unambiguously applies to all vehicles operated in Wisconsin, not just those that are also registered in Wisconsin.  We note that the very next subsection, § 341.15(1m), sets out requirements for “any registration decal or tag issued by the department.”  (Emphasis added.)  Obviously, if the legislature had wanted to limit § 341.15(1) to cars issued two plates in the state of Wisconsin, it could have done so by stating that “whenever 2 registration plates are issued by the department, one plate shall be attached to the front and one to the rear ….”[3]  Boyd’s argument essentially asks us to read that extra language into the statute, which is something we may not do.  See Burbank Grease Servs., LLC v. Sokolowski, 2006 WI 103, ¶¶24-25, 294 Wis. 2d 274, 717 N.W.2d 781.  We therefore hold that § 341.15(1) applies to all vehicles driven in the state of Wisconsin, not just those registered here.

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