Only reply I can give you is to ask for statutes.  It is the verbage in the statutes that determines whether you win or lose in court.  DMV should be able to quote scripture and verse to speak..........and make sure the scripture and verse is in reference to what you are asking.  Too many times someone pulls a law out that is in reference to another item.  Also, be aware of the definitions applicable to a statute.

Not saying you are wrong, but I have played against state and national "intelligence" long enough to know they can be as wrong as we are.

As I stated before, use a license you are comfortable with and let the chips fall where they may.  A lawyer will probably get to sort it out in the end anyway.