Open Records Decision No. 341
December 31, 1982

	Re:  Whether numbers on Texas driver's license representing Department of 
Public Safety station which issues license are open to public

Mr. John C. West, Jr.
Assistant General Counsel
Texas Department of Public Safety
P. O. Box 4087
Austin, Texas  78773

Dear Mr. West:

	Recently issued Texas driver's licenses contain an eleven digit number known as 
the “DPS Code.”  We are informed that the various digits in this code signify the year, 
the date on which the licensee applied for the license, the Department of Public Safety 
[hereinafter DPS] driver's license office which issued the license, the camera which was 
used to photograph the licensee, and the particular frame on the roll of film in which the 
licensee appears.

	You have received a request under the Open Records Act, article 6252-17a, 
V.T.C.S., for:

a list of the addresses of each Department of Public Safety station 
for the issuance of Texas Driver's Licenses together with the 
corresponding code designation which identifies said station within 
the above mentioned DPS Code.

You contend that this information is protected from required disclosure by section 
3(a)(8) of the act, which excepts:

records of law enforcement agencies that deal with the detection and 
investigation of crime and the internal records and notations of such 
law enforcement agencies which are maintained for internal use in 
matters relating to law enforcement.

	In your letter to this office, you stated:

[T]he information in question is utilized by commissioned officers 
of [DPS] in ascertaining whether or not a particular driver's license 
is duly issued by [DPS] . . . . [T]he numbers now sought are unique 
to each driver's license.  As a part of the code, the identifiers are 
utilized to indicate which station issued a license.  This identifier 
conveys to a member of this [d]epartment certain information that 
he may utilize to determine if the license is a forgery . . .  [I]f an 
individual had access to those numbers . . . it would diminish 
significantly the possibilities of detecting a forgery or fictitious 
license through utilization of the code.  For example, certain 
numbers that would be utilized in the three spaces of code indicating 
the station identifier, would be impossible numbers, as we do not 
have stations number[ed] in that particular manner . . . .

	In summary, it [is] our position that this unique number, if 
made available generally, would give undue advantage to an 
individual who desired to forge and/or counterfeit Texas drivers' 
licenses.

	Section 32 of article 6687b, V.T.C.S., makes it unlawful for any person to 
possess a fictitious driver's license.  A violation of this section constitutes a 
misdemeanor.  V.T.C.S. art 6687b, §44.

	As our prior Open Records Decisions indicate, see, e.g., Open Records Decision 
Nos. 313 (1982); 287 (1981), the Texas Supreme Court appears to have taken the 
position that information may be withheld under section 3(a)(8) if its release would 
unduly interfere with law enforcement.  See Ex parte Pruitt, 551 S.W.2d 706 (Tex. 
1977).  In our opinion, this standard has been met in this instance.

	We believe that the release of the addresses of the DPS driver's license stations 
and their corresponding code numbers would significantly hamper DPS in its efforts to 
detect license forgeries.  If this information is made available to the public, the 
department will lose one of its most effective means of detecting forgeries.  We therefore 
conclude that section 3(a)(8) authorizes you to deny the request for this information.

Very truly yours,

Mark White
Attorney General of Texas

John W. Fainter, Jr.
First Assistant Attorney General

Richard E. Gray III
Executive Assistant Attorney General

Prepared by Jon Bible
Assistant Attorney General

APPROVED:
OPINION COMMITTEE

Susan L. Garrison, Chairman
Jon Bible
Patricia Hinojosa
Jim Moellinger
Bruce Youngblood