People v. Doyle was a California Supreme Court case. It established that a person convicted of a non-violent DUI crime could still be sentenced as a violent felon if they had a previous DUI manslaughter conviction or other similar past convictions. Under California’s Three Strikes Law, this means a potential sentence of 25 years to life in prison.
California has an unpopular “Three Strikes” law which was originally passed in the 1990s and has been reformed several times since. This law is designed to keep violent repeat criminals off the streets. It makes every violent felony conviction count as a “strike,” and requires a mandatory 25 years to life prison sentence for third strike offenders.
Since DUI is not normally a violent crime, DUI convictions only originally counted as strikes if:
- They resulted in great bodily harm to someone
- They were charged as DUI manslaughter or DUI murder
The court decision known as People v. Doyle changed that.
Background of People v. Doyle
Douglas Doyle was originally convicted of DUI manslaughter in 1988. In that case, he had struck another vehicle and killed the driver. This was his first “strike.”
His second strike came in 2007 when he was convicted of an assault charge.
In 2008, Doyle was again pulled over for DUI—although this time, no one was hurt. There wasn’t even an accident. Police simply saw his car weaving and arrested him for DUI after pulling him over safely.
This kind of DUI is not usually a felony, even for a repeat offender, and it does not count as a strike. But in California, prosecutors can charge it as a felony if the driver already had a past DUI manslaughter conviction—which Doyle did. Thus, his new 2008 DUI was charged as a felony. But since no one was hurt or killed, it was not the kind of felony DUI that would normally be a strike.
The prosecutor disagreed. In their line of reasoning, the new charge was a felony because it was upgraded by the manslaughter charge. The prosecutor sought a “third strike” and sought the mandatory sentence. The judge in Doyle’s case agreed and Doyle was sentenced to 25 years to life for a nonviolent DUI.
A Bad Day for DUI Law
The judge’s decision was controversial, and set a terrible precedent for other DUI cases. Doyle’s lawyer chose to fight it. First they appealed to the California Court of Appeals, and eventually the case went all the way to the California Supreme Court.
Doyle’s lawyer argued that his sentence was a case of “impermissible bootstrapping.” This is a legal term that means the prosecutor used technicalities to drive up Doyle’s sentence beyond what it was legally supposed to be. They also argued for a case of cruel and unusual punishment, and violations of Doyle’s rights, including the right to due process.
On October 29, 2013, the state Supreme Court issued its verdict. They upheld Doyle’s sentence, affirming that it is acceptable to count his felony DUI conviction as a “strike.”
How does People. v. Doyle affect my DUI case?
If neither your current DUI, nor any past DUI involves death or serious injuries, you can breathe a sigh of relief—it’s unlikely that the Doyle decision will affect your case.
However, if you are facing a current DUI charge, and you have ever been previously convicted of a felony DUI involving injury or death, it is imperative that you fight your new case to the full extent of the law. If your past DUI conviction was counted as a “strike,” it means there is a chance that your new DUI will also be a strike—regardless of the circumstances of how it happened. It does not matter how long ago your previous conviction was.
This situation is even more urgent if you have other felony convictions on your record. If your DUI becomes the third strike, you will face a potential lifetime in prison. As Doyle found out, it’s very hard to go back and fight the sentence after it is passed—it is much more effective to fight your DUI case now and try to beat the charge. You need to speak to a lawyer.
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