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It is Maryland court lingo.
It most likely means not legally licensed.
§ 16-305. Permitting vehicle to be driven by unauthorized person or in violation of title.
(a) Permitting vehicles to be driven by certain persons.- A person may not knowingly permit a motor vehicle owned by him to be driven on any highway by any person:
(1) If the person is not authorized by this title to drive; or
(2) Otherwise in violation of any of the provisions of this title.
(b) Vehicles under person's control.- A person may not knowingly permit a motor vehicle under the person's control to be driven on any highway by any person:
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