People v. Doyle
220 Cal. App. 4th 1251
Cal. Ct. App.2013Background
- In 1988 Doyle pleaded guilty to DUI manslaughter after driving under the influence and causing a fatal collision. He later committed other offenses, including assault with a deadly weapon (2007).
- In 2008 Doyle was arrested for a new DUI. The DA charged the new DUI as a felony under Vehicle Code §23550.5(b) because of the 1988 DUI manslaughter prior; the information also alleged two prior strikes (1988 DUI manslaughter and 2007 assault) and prior prison terms.
- Doyle pleaded guilty to felony DUI (with prior DUI manslaughter) and admitted the priors, exposing him to Three Strikes sentencing; the trial court denied his Romero motion and sentenced him to 25 years to life under the Three Strikes law.
- On appeal Doyle argued it was unlawful (and unconstitutional) to use the 1988 DUI manslaughter both to elevate the current DUI to a felony and to serve as a strike, and he raised equal protection, due process, cruel-and-unusual punishment, double jeopardy, and abuse-of-discretion claims regarding the Romero denial.
- The Court of Appeal rejected Doyle’s statutory and constitutional arguments, concluding statutes and precedent permit using a prior conviction both to elevate a current wobbler and to trigger Three Strikes, and that Doyle’s equal protection and other constitutional claims lacked merit.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Doyle) | Held |
|---|---|---|---|
| Use of prior DUI manslaughter both to elevate current DUI to a felony and to serve as a Three Strikes prior | Statutory scheme permits both uses; Three Strikes applies “in addition to any other enhancement or punishment provisions” | Using the same prior conviction twice is impermissible "bootstrapping" and should be disallowed | Permitted: statutes and precedent (e.g., White Eagle, Coronado) allow dual use; no legislative intent to preclude it |
| Equal protection challenge to disparate treatment (DUI manslaughter prior vs. Watson murder prior) | Classification is rational: DUI manslaughter and Watson murder differ in culpability and sentencing, so groups are not similarly situated | Disparate treatment is arbitrary: manslaughter prior can result in harsher later punishment than a prior Watson murder | Rejected: groups not similarly situated; rational basis exists for different legislative treatment |
| Denial of Romero motion to strike priors (abuse of discretion) | The court properly applied Romero/Williams factors and reasonably concluded defendant fell within Three Strikes spirit | Court abused discretion, misunderstood scope of authority, and should have struck a prior because of double-counting and mitigating facts | Denial affirmed: no abuse of discretion—court considered factors and gave reasoned analysis |
| Cruel and unusual / double jeopardy claims from double use of prior | Recidivist statutes rationally punish repeat offenders; dual use not double jeopardy or cruel and unusual | Dual use is "freakish," amounts to double punishment and violates double jeopardy and Eighth Amendment | Rejected: dual use fits recidivist rationale, is neither cruel nor unusual, and does not implicate double jeopardy under controlling precedent |
Key Cases Cited
- People v. White Eagle, 48 Cal.App.4th 1511 (Cal. Ct. App.) (prior used to elevate current wobbler may also be used as a Three Strikes prior)
- People v. Coronado, 12 Cal.4th 145 (Cal. 1995) (use of prior DUI convictions for elevation and enhancement consistent with legislative intent)
- People v. Briceno, 34 Cal.4th 451 (Cal. 2004) (interpretation limiting "bootstrapping" depends on voters’/legislative intent)
- In re Shull, 23 Cal.2d 745 (Cal. 1944) (court construes legislative intent to avoid applying an enhancement where statute implicitly precludes it)
- People v. Ireland, 70 Cal.2d 522 (Cal. 1969) (merger doctrine in felony-murder context and anti-bootstrapping reasoning)
- People v. Hofsheier, 37 Cal.4th 1185 (Cal. 2006) (equal protection: different crimes may be similarly situated in limited circumstances; requires rational basis review)
- People v. Carmony, 33 Cal.4th 367 (Cal. 2004) (standards for reviewing denial of Romero motion for abuse of discretion)
- Rummel v. Estelle, 445 U.S. 263 (U.S. 1980) (upholding recidivist sentencing rationale against Eighth Amendment challenge)