State of Louisiana v. Ethan M. Doyle

Judgment rendered November 19, 2025.
Application for rehearing may be filed
within the delay allowed by Art. 922,
La. C. Cr. P.

No. 56,576-KA

COURT OF APPEAL
SECOND CIRCUIT
STATE OF LOUISIANA

*****

STATE OF LOUISIANA Appellee

versus

ETHAN M. DOYLE Appellant

*****

Appealed from the
First Judicial District Court for the
Parish of Caddo, Louisiana
Trial Court No. 400,743

Honorable Donald Edgar Hathaway, Jr., Judge

*****

LOUISIANA APPELLATE PROJECT Counsel for Appellant
By: Edward Kelly Bauman

JAMES EDWARD STEWART, SR. Counsel for Appellee
District Attorney

STEPHEN FOLK-CRUTHIRDS
ERIC MATTHEW WHITEHEAD
Assistant District Attorneys

*****

Before STONE, THOMPSON, and ELLENDER, JJ.

STONE, J.

This criminal appeal arises from the First Judicial District Court, the

Honorable Donald Hathaway presiding. Ethan M. Doyle (“Doyle”), the

defendant, was charged with aggravated flight from an officer (La. R.S.

14:108.1) and aggravated obstruction of a highway (La. R.S. 14:96). The

latter carries a maximum sentence of 15 years, while the former carries a

maximum of 5 years. After a jury trial, the defendant was convicted on both

counts. Thereafter, the court ordered and obtained a presentence

investigation report (“PSI”), and sentenced Doyle to 5 years on both counts,

to run concurrently. Doyle now appeals his conviction and sentences, urging

the following assignments of error: (1) his trial counsel was ineffective

because he failed to file a motion to suppress and/or quash the bill; (2) his

conviction for both offenses violates double jeopardy; and (3) his maximum

sentences are excessive.

On March 9, 2024, Deputy Adrian Ruffin (“Dpty. Ruffin”) of the

Shreveport Police Department observed the defendant’s vehicle traveling on

North Market Street with a black garbage bag covering the rear driver-side

door window—thus blocking defendant’s ability to see through that window

as he drove the vehicle. Dpty. Ruffin also stated that the bag was not secure.

Finding this suspicious for the traffic offense of improper equipment, Dpty.

Ruffin activated his lights on his patrol unit. Doyle initially pulled over and

stopped, but then blasted off as Dpty. Ruffin was preparing to get out of his

police unit. Dpty. Ruffin gave chase all the way into Bossier City but

terminated his pursuit on Hwy 71 when he felt it was too dangerous as

Doyle was “weaving in and out of traffic.” Dpty. Ruffin stated that there

was at least one other person in the car with Doyle during the chase.

However, Dpty. Ruffin’s dashcam recording was not introduced into

evidence.

Later, upon identifying the Doyle vehicle at the intersection of Hwy

71 and Hwy 173, Caddo Parish Sherriff’s Deputy Cory Bourn (“Dpty.

Bourn”) activated his lights and Doyle fled again. The chase resumed and

Doyle’s vehicle was eventually stopped with the use of spike strips. Dpty.

Bourn reported that he observed the defendant traveling at 105 mph in a 55

mph speed zone, 85 mph in a 45 mph zone in the residential area of Hosston,

and over 100 mph on Interstate 49; Caddo Parish Sherriff’s Deputy Keith

Morgan (“Dpty. Morgan”), who followed behind Dpty. Bourn in the latter

chase, reported the defendant traveling at 114 mph in a 75 mph zone on

Interstate 49. As his dashcam footage was played for the jury, Dpty. Bourn

testified that Doyle drove in the opposing lane to pass another vehicle.

Doyle was Mirandized and arrested after officers stopped him. Doyle

complied with officers’ commands once stopped. When asked why he did

not stop, Doyle claimed he did not know police were pursuing him. In the

police bodycam video, his movement and speech were noticeably slow, and

his demeanor was quiet and subdued. One officer commented that there was

an open alcoholic beverage container in the car.

Nobody else was in the vehicle when officers finally stopped Doyle.

However, the car did contain a wallet belonging to another person with

outstanding arrest warrants for possession of methamphetamine and crack

cocaine. Doyle’s wallet contained $489 cash. Bodycam video recorded

officers discussing the matter and inferred that Doyle had dropped off his

passenger(s) in between the two pursuits and had potentially eaten all the

2

(suspected) drugs; they were concerned he would die of overdose in the

police vehicle, and they discussed bringing him to the hospital before jail.

In Doyle’s PSI interview, he stated:
First, I would like to take responsibility for my actions. I
do understand the risk to public safety that I caused. I am
extremely grateful that nobody was hurt as a result of my
actions. At the time of my arrest, I was dealing with
recent death of my grandfather, and [another close family
member had been diagnosed with leukemia]. I was
depressed and made a poor decision that day. I had
relapsed on alcohol, losing several years of sobriety.
Doyle also stated that he had completed “Change the World” and “Anger

Management” classes while awaiting trial and had been accepted to CADA1

for inpatient addiction treatment and 3 months of sober living.

Doyle’s record of arrests and prosecutions (“RAP sheet”) is also in the

record. He has quite a history with marijuana. In 2011, he was twice

arrested for misdemeanor possession of marijuana; both resulted in

prosecutorial charges filed but later dismissed. In 2012, he was arrested for

felony burglary but no charges were filed. In 2013, he was: (1) charged with

a felony drug offense but convicted only of misdemeanor marijuana

possession; (2) in a separate incident, he was arrested and charged separately

for another instance of misdemeanor marijuana possession (charges

dismissed); and (3) twice charged and convicted for misdemeanor theft

(stemming from two separate incidents). In 2021, Doyle was again

convicted of misdemeanor marijuana possession, and three weeks later was

arrested for misdemeanor theft.

After Doyle was sentenced, he did not file a motion to reconsider

sentence.

1
This is an acronym for Council on Alcoholism & Drug Abuse.
3

Justification for initial stop

Relevant to Dpty. Ruffin’s reason for initially attempting to stop

Doyle, La. R.S. 32:53(A)(1) states:

No person shall drive…on any highway of this
state…any vehicle… which is in such unsafe condition
as to endanger any person or property.

Aggravated flight

On the date of the offense, La. R.S. 14:108.1, in relevant part,

provided:

C. Aggravated flight from an officer is the intentional
refusal of a driver to bring a vehicle to a stop…under
circumstances wherein human life is endangered, knowing
that he has been given a visual and audible signal to stop
by a police officer when the officer has reasonable grounds
to believe that the driver or operator has committed an
offense. The signal shall be given by an emergency light
and a siren on a vehicle marked as a police vehicle...
D. Circumstances wherein human life is endangered shall
be any situation where the operator of the fleeing vehicle
or watercraft commits at least two of the following acts:
(1) Leaves the roadway or forces another vehicle to leave
the roadway.
(2) Collides with another vehicle...
(3) Exceeds the posted speed limit by at least twenty-five
miles per hour.
(4) Travels against the flow of traffic...
(5) Fails to obey a stop sign or a yield sign.
(6) Fails to obey a traffic control signal device.
E. (1) Whoever commits aggravated flight from an officer
shall be imprisoned at hard labor for not more than five
years and may be fined not more than two thousand
dollars.2

2
Paragraph (2) of subsection (E) provides a higher potential penalty if the
defendant causes serious bodily injury: “Whoever commits the crime of aggravated
flight from an officer that results in serious bodily injury shall be imprisoned at hard
labor for not more than ten years and may be fined not more than two thousand dollars.”

4

Thus, the elements of this crime are: (1) intentional refusal by a driver to

stop his vehicle; (2) despite knowing that a police officer has given him a

visual and audible signal to stop; (3) the police officer has reasonable

suspicion for the stop; (4) such refusal to stop involves two or more of the

six following circumstances: a vehicular collision, speeding by 25mph or

more, driving the wrong way down the street, failure to obey a stop sign,

yield sign, or traffic light.

Aggravated obstruction of a highway
In pertinent part, La. R.S. 14:96 provides:
A. Aggravated obstruction of a highway of commerce is
the intentional or criminally negligent…performance of
any act on any… road, highway, [or] thoroughfare wherein
it is foreseeable that human life might be endangered.
B. Whoever commits the crime of aggravated obstruction
of a highway of commerce shall be imprisoned, with or
without hard labor, for not more than fifteen years.
Thus, the elements of this crime are: (1) performance of an intentional or

criminally negligent act on any road; (2) wherein it is foreseeable that

human life might be endangered.

Suppression; ineffective assistance
As explained more fully below, Doyle argues: (1) that his arrest was

illegal because the “initial attempted stop” was unjustified, and, therefore,

evidence derived from that constitutional violation should have been

suppressed; and therefore, (2) his trial counsel was ineffective in failing to

move to suppress the evidence. Doyle also relates his aggravated flight from

the officer to the (lawful) resistance of an unlawful arrest.

Suppression. In State v. Robinson, 52,974 (La. App. 2 Cir. 3/18/20),

293 So. 3d 193, 201, writ denied, 20-00525 (La. 10/20/20), 303 So. 3d 315,

5

we explained the constitutional boundaries on searches and seizures by law

enforcement:

The right of every person to be secure in his person, house,
papers, and effects against unreasonable searches and
seizures is guaranteed by the Fourth Amendment to the
United States Constitution and Article I, § 5 of the
Louisiana Constitution. However, that declaration of rights
“presupposes that there must be an invasion of [the] right
to privacy before there can be an unreasonable search.”
State v. Jackson, 09-1983 (La. 7/6/10), 42 So. 3d 368.
(Emphasis added). Simply stated, if there has been no
“search” or “seizure,” as defined by the constitutional
jurisprudence, then there cannot be a constitutional
violation. With regard to whether a search has occurred,
the inquiry is whether there was “an objectively
reasonable expectation of privacy in the area.” Id.

In California v. Hodari D., 499 U.S. 621, 111 S.Ct. 1547, 113 L.Ed.2d

690 (1991), the United States Supreme Court held that an individual is not

“seized” within the meaning of the Fourth Amendment until that individual

either submits to the police show of authority or is physically contacted by

the police. In State v. Tucker, 626 So. 2d 707, 712-13 (La.), opinion

reinstated on reh’g, 626 So. 2d 720 (La. 1993), the Louisiana Supreme

Court adopted Hodari D., but also held that the Louisiana constitution

provides more protection than its federal counterpart:

Today we adopt Hodari D.’s definition for determining
when an “actual stop” has occurred. We additionally adopt
a standard for determining [under the Louisiana
constitution's additional protection] the “imminency” of an
actual stop which focuses on whether an “actual stop” is
“virtually certain” to result from the police encounter. To
the extent this decision conflicts with our prior decisions,
they are hereby overruled.
Id. Tucker articulated the additional protection as follows:

In determining whether an “actual stop” of an individual is
“imminent,” we find that the focus must be on the degree
of certainty that the individual will be “actually stopped”
as a result of the police encounter...It is only when the

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police come upon an individual with such force that,
regardless of the individual's attempts to flee or elude the
encounter, an actual stop of the individual is virtually
certain, that an “actual stop” of the individual is
“imminent.”
Id. Tucker also provided a list of factors a court may consider in

determining when an imminent actual stop was virtually certain:

[T]he following factors may be useful in assessing the
extent of police force employed and determining whether
that force was virtually certain to result in an “actual stop”
of the individual: (1) the proximity of the police in relation
to the defendant at the outset of the encounter; (2) whether
the individual has been surrounded by the police; (3)
whether the police approached the individual with their
weapons drawn; (4) whether the police and/or the
individual are on foot or in motorized vehicles during the
encounter; (5) the location and characteristics of the area
where the encounter takes place; and (6) the number of
police officers involved in the encounter.
Id.

In relevant part, La. C. Cr. P. art. 703 provides:

A. A defendant adversely affected may move to suppress
any evidence from use at the trial on the merits on the
ground that it was unconstitutionally obtained.
...
C. A motion filed under the provisions of this Article must
be filed in accordance with Article 521,4 unless
opportunity therefor did not exist or neither the defendant
nor his counsel was aware of the existence of the evidence
or the ground of the motion, or unless the failure to file the
motion was otherwise excusable. The court in its
discretion may permit the filing of a motion to suppress at
any time before or during the trial.
D. On the trial of a motion to suppress filed under the
provisions of this Article, the burden of proof is on the
defendant to prove the ground of his motion, except that
the state shall have the burden of proving the admissibility
of a purported confession or statement by the defendant or
of any evidence seized without a warrant.
E. (1) An evidentiary hearing on a motion to suppress shall
be held only when the defendant alleges facts that would

7

require the granting of relief. The state may file an answer
to the motion.
...
F. A ruling prior to trial on the merits, upon a motion to
suppress, is binding at the trial. Failure to file a **6
motion to suppress evidence in accordance with this
Article prevents the defendant from objecting to its
admissibility at the trial on the merits on a ground
assertable by a motion to suppress.
In Robinson, supra, we also explained the procedural and evidentiary

aspects of enforcing these constitutional freedoms:

Generally, if evidence was derived from an unlawful
search or seizure, the proper remedy is exclusion of the
evidence from trial. On a motion to suppress evidence on
the ground that it was unconstitutionally obtained, the
prosecution has the burden of proving the admissibility of
any evidence seized without a warrant. La. C.Cr.P. art.
703(D).
The standard of review applicable to a trial court's decision
on a motion to suppress is bifurcated as follows: (1) legal
findings or conclusions are subject to de novo review; and
(2) findings of fact are subject to manifest error review.
Manifest error review requires great deference to the
factfinder's decisions regarding witness credibility.
Id.

This court recently addressed an argument virtually identical to

Doyle’s in State v. Riggs, 55,736 (La. App. 2 Cir. 7/23/25), ---So.3d---.

There, Riggs drove past an officer who then began following Riggs’s vehicle

due to its suspected excessive muffler noise. Riggs abruptly accelerated—

violating the speed limit--before the officer turned on his lights. The officer

pursued, and after a long chase, Riggs drove his vehicle off a bridge and into

a bayou, and was then rescued from the vehicle and arrested. Riggs argued

that all evidence obtained after the officer began following him had to be

suppressed because there was no reasonable suspicion at the time the officer

8

began following him. Pursuant to Hodari D., supra, and Tucker, supra, we

rejected that argument, stating:

By the time that Riggs unintentionally cast himself into the
bayou, the officers already had acquired the evidence
needed to convict Riggs of aggravated flight from an
officer. Riggs was not virtually certain to imminently be
stopped until he had already been recorded on video
speeding and committing aggravated flight from an officer.
The exclusionary sanction, by definition, only excludes
evidence derived from an unlawful arrest, detention,
search, or seizure. Given the facts of this case, it is
logically impossible that the testimony and video of what
Riggs did before his vehicle was stopped was derived from
the stop of his vehicle. That is so under the rule of Hodari
D., supra, and the heightened protection under Tucker,
supra. Thus, even assuming for the sake of argument that
the officer lacked reasonable suspicion at the time he
began to follow Riggs, the trial court was correct in
denying the motion to suppress such evidence.
Furthermore, the officer had probable cause to arrest Riggs
by the time the arrest was actually made as the officer had
quite personal knowledge that Riggs was speeding and
committing flight from the arresting officer himself.
Riggs's arrest was lawful. Therefore, any evidence derived
from the arrest, such as confirming Riggs's identity as the
driver, is not subject to suppression under either the
federal constitution or Louisiana constitution.
Id. The constitution only prohibits unreasonable searches and seizures, and

thus the exclusionary sanction does not attach until the suspect is seized.

Doyle argues that the bag over his window did not constitute a

violation of La. R.S. 32:53(A)(1), supra, and therefore, Dpty. Ruffin lacked

reasonable suspicion to attempt to stop him. The statute states: “No person

shall drive…on any highway of this state…any vehicle…which is in such

unsafe condition as to endanger any person or property.” Doyle also creates

a strawman to pummel in suggesting that Dpty. Ruffin had in mind La. R.S.

32:361, which only prevents covering of the front windshield and front

windows.

9

Doyle’s argument for suppression is without merit for the reasons set

forth in Riggs, supra. Even if it is assumed for the sake of argument that the

initial attempted stop was unlawful, it makes no difference. No evidence

gathered before Doyle was arrested could possibly be derived from his

arrest; accordingly, such evidence is categorically beyond the exclusionary

sanction. Robinson, supra; Riggs, supra. The moment Doyle violated the

speed limit by even one mile per hour in fleeing Dpty. Ruffin, he had

probable cause to arrest Doyle. Having escaped Dpty. Ruffin’s pursuit,

Doyle grossly violated the speed limit and other traffic laws when Dpty.

Bourn resumed that pursuit. Thus, when the officers finally arrested Doyle,

there (emphatically) was probable cause. Tucker, supra; Hodari D., supra.3

Therefore, Doyle has failed to show that his trial counsel was ineffective.

Double jeopardy

The double jeopardy clause of U.S. Const. amend. V provides: “No

person shall…be subject for the same offence to be twice put in jeopardy of

life or limb.” The double jeopardy clause of La. Const. art. I, § 15 likewise

states: “No person shall be twice placed in jeopardy for the same offense.”

In State v. Frank, 16-1160 (La. 10/18/17), 234 So. 3d 27, the

Louisiana Supreme Court re-established the “Blockburger test” as the sole

standard for determining whether the prohibition against double jeopardy

has been violated in a particular case, thereby abrogating the “same evidence

test” that was for a time used in addition to the “Blockburger test.”

3
Furthermore, assuming arguendo that the initial attempted stop was unlawful,
such did not exempt Doyle, in his resistance thereto, from applicability of traffic laws or
give him the privilege of recklessly endangering human life without legal consequences.
Thus, Doyle’s claim regarding “resisting an unlawful arrest” is meritless.
10

Blockburger holds that if a defendant is to be convicted of two crimes

arising for the same criminal incident, then each crime must have an

essential element that the other does not; otherwise, double jeopardy is

violated. Id.

State v. Holley, 53,405 (La. App. 2 Cir. 4/22/20), 297 So. 3d 180, 185,

writ denied, 20-00923 (La. 11/10/20), 303 So. 3d 1036.

The guarantee against double jeopardy provides three
central constitutional protections: (1) protection against a
second prosecution for the same offense after acquittal; (2)
protection against a second prosecution for the same
offense after conviction; and (3) protection against
multiple punishments for the same offense. State v.
Crandell, 05-1060 (La. 3/10/06), 924 So. 2d 122.
…
Double jeopardy bars separate punishment of lesser
included offenses once the defendant is convicted of the
greater offense. State v. Price, 39,582 (La. App. 2 Cir.
3/23/05), 899 So.2d 633. The double jeopardy clause
prohibits prosecution for both a felony murder and the
underlying felony. State v. Thomas, 50,929 (La. App. 2 Cir.
8/10/16), 201 So. 3d 263, 278, writ denied, 16-1642 (La.
9/6/17), 224 So. 3d 980. To remedy a violation of double
jeopardy, the reviewing court normally vacates the
conviction and sentence of the less severely punishable
offense, and affirms the conviction and sentence of the
more severely punishable offense. Price, supra.
However, State v. Kirsh, 17-0231 (La. App. 1 Cir. 11/1/17), 234 So. 3d

941, 948, writ denied, 17-2169 (La. 11/20/18), 256 So. 3d 993,4 makes a

critical distinction:

The prohibition against double jeopardy is not violated,
however, when the defendant is prosecuted for different
criminal acts committed during one sequential, continuing
course of conduct. In those instances, the defendant is not
being punished twice for the same act. Rather, he has
committed and can be prosecuted for separate crimes
attributable to separate and distinct acts that occurred
successively. Because the evidence showed that two

4
Kirsch cited Frank, supra, and applied only the Blockburger test.
11

separate crimes occurred, each of which could have been
proven without any evidence as to the other, no double
jeopardy violation occurred. (Internal citations and
quotation marks omitted.)
Thus, in this case, the state divides the event into distinct crimes

committed sequentially, arguing:

When Doyle traveled in the wrong lane at high speeds
through residential areas in multiple towns (Gilliam and
Hosston), he intentionally performed an act wherein it is
foreseeable that human life might be endangered. These
acts distinctly
and independently constituted Aggravated Obstruction of a
Highway. When Doyle, having been given audible and
visual signals to stop, fled at speeds nearly doubling
the posted speed limit against the flow of traffic, leaving
the roadway, and causing others to leave the road and
lanes of travel, he actually endangered human life. These
acts distinctly and independently constituted Aggravated
Flight from an Officer.

The evidence supports the state’s position. Doyle escaped the first

pursuit by making it too dangerous for Dpty. Ruffin to maintain. Thereafter,

Doyle led other law enforcement officers on a second high-speed chase once

he was identified as the escapee of the first pursuit. Thus, the evidence

proves two separate, sequential crimes that were part of the same criminal

episode. This assignment of error lacks merit and is rejected. Likewise,

Doyle’s trial counsel was not ineffective in declining to file a motion to

quash.

Excessive sentence
In State v. Boswell, 56,200 (La. App. 2 Cir. 4/9/25) 409 So. 3d 491, we

recently reiterated the law concerning excessive sentence claims:

An excessive sentence claim is reviewed by examining
whether the trial court adequately considered the
guidelines established in La. C. Cr. P. art. 894.1 and
whether the sentence is constitutionally excessive.
Ordinarily, appellate review of sentences for excessiveness
utilizes a two-prong process. However, when the motion to
reconsider sentence raises only a claim of constitutional
12

excessiveness, a defendant is relegated [under La. C. Cr. P.
art. 881.1(E)] to review of the sentence on that ground
alone.
Boswell, by failing to state specific grounds for his motion
to reconsider sentence, has waived his right to have his
sentence reviewed for compliance with art. 894.1. As a
result, the remaining question is whether his sentence
exceeds the punishment allowed by the state and federal
constitutions.
The Eighth Amendment of the United States Constitution
and Article I, § 20 of the Louisiana Constitution prohibit
the imposition of cruel or excessive punishment. Although
a sentence falls within statutory limits, it may be
excessive.
The appellate court must determine if the sentence is
constitutionally excessive. To assess a claim that a
sentence violates La. Const. art. I, § 20, the appellate court
must determine if the sentence is grossly disproportionate
to the seriousness of the offense or nothing more than a
purposeless and needless infliction of pain and suffering. A
sentence is considered grossly disproportionate if, when
the crime and punishment are viewed in light of the harm
done to society, it shocks the sense of justice.
The sentencing court has wide discretion to impose a
sentence within the statutory limits, and the sentence
imposed will not be set aside as excessive absent a
manifest abuse of that discretion. On review, an appellate
court does not determine whether another sentence may
have been more appropriate, but whether the trial court
abused its discretion. (Internal case citations omitted.)

Regarding maximum sentences, this court has stated:
Maximum sentences are generally reserved for the “most
egregious and blameworthy offenders in a class.” As a
general rule, maximum or near maximum sentences are
reserved for the worst offenders and the worst offenses.
State v. Cozzetto, 2007–2031 (La.02/15/08), 974 So.2d
665; State v. Hogan, 47,993 (La.App.2d Cir.04/10/13), 113
So.3d 1195, writ denied, 2013–0977 (La.11/08/13), 125
So.3d 445. The trial court is given wide discretion in the
imposition of sentences within the statutory limits. Such a
sentence will not be set aside as excessive absent a
manifest abuse of that discretion. State v. Williams, 2003–
3514 (La.12/13/04), 893 So.2d 7; State v. Diaz, 46,750
(La.App.2d Cir.12/14/11), 81 So.3d 228.

State v. Cotten, 50,747 (La. App. 2 Cir. 8/10/16), 201 So. 3d 299, 302.

13

Because Doyle did not file a motion to reconsider sentence, our

review is limited strictly to determining constitutional excessiveness.

La. R.S. 14:108.1(E)(1) carries a maximum potential incarceration

period of 5 years; for La. R.S. 14:96, the maximum is 15 years. The trial

court sentenced the defendant to 5 years on both convictions and ordered

that the sentences run concurrently.

Doyle argues that his sentence is excessive because: (1) he is a first

time felony offender with only misdemeanors on his record; (2) no harm to

person or property resulted from his actions; (3) he graduated high school

and worked as a driver for a casino; and (4) nothing indicates that he could

not be rehabilitated or would be a danger to society if released earlier.

The state rebuts item “(2)” in Doyle’s argument on the ground that if

serious bodily injury results, a distinct type of aggravated flight occurs and a

separate penal provision applies, raising the maximum possible sentence to

ten years. La. R.S. 14:108.1(E)(2). From this premise, the state argues that

Doyle’s claim to mitigation on the ground that he did not hurt anyone is

invalid. The state also emphasizes the severity and danger of the particular

facts of Doyle’s crimes herein.

It is true that Doyle did not kill or maim anyone. Nor did he destroy

the property of others. However, this was not by merit of his own. The

magnitude of the harm that he could have foreseeably caused is vast.

Moreover, the trial court was within its authority to consider, for sentencing

purposes, Doyle’s RAP sheet and officer testimony indicating that, after

escaping the first pursuit, Doyle had dropped off a passenger who had

outstanding arrest warrants for possession of methamphetamine and cocaine.

This evidence impeaches Doyle’s claim that his tenacious and persistent
14

flight was completely irrational and driven solely by emotional pain—rather

than hiding his apparent association with drug-involved individuals. Doyle’s

effective aggregate sentence of five years for his two felony convictions is

not in excess of constitutional boundaries.

CONCLUSION

Ethan M. Doyle’s convictions and sentences are AFFIRMED and his

ineffective assistance claim is DENIED.

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