Critchfield received his fourth DUI conviction in 1987, resulting in permanent revocation of his driver's license. In 1999 he applied for a hardship license, but was denied on the ground that a 1998 statute barred his eligibility. He sued and contended in part that the 1998 statute violated the single-subject requirement imposed by the Florida Constitution. The trial court agreed, and declared the law unconstitutional. The Fifth District Court affirmed.