State v. Doucette

• Court: Ohio Court of Appeals
• Decided: June 26, 2026
• Docket: 2025-CA-67
• Status: Published

Opinion

[Cite as State v. Doucette, 2026-Ohio-2426.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT CLARK COUNTY

STATE OF OHIO : : C.A. No. 2025-CA-67 Appellee : : Trial Court Case No. 25-CR-395 v. : : (Criminal Appeal from Common Pleas BLAKE DOUCETTE : Court) : Appellant : FINAL JUDGMENT ENTRY & : OPINION

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Pursuant to the opinion of this court rendered on June 26, 2026, the judgment of the

trial court is affirmed.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately

serve notice of this judgment upon all parties and make a note in the docket of the service.

Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified

copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note

the service on the appellate docket.

For the court,

RONALD C. LEWIS, PRESIDING JUDGE

HUFFMAN, J., and HANSEMAN, J., concur. OPINION CLARK C.A. No. 2025-CA-67

ADAM J. ARNOLD, Attorney for Appellant JOHN M. LINTZ, Attorney for Appellee

LEWIS, P.J.

{¶ 1} Defendant-appellant Blake Doucette appeals from his conviction in the Clark

County Common Pleas Court following a guilty plea. For the following reasons, we affirm

the judgment of the trial court.

I. Facts and Course of Proceedings

{¶ 2} On May 20, 2025, Doucette was indicted by a Clark County grand jury on one

count of failure to comply with an order or signal of a police officer, a third-degree felony in

violation of R.C. 2921.331(B), and one count of receiving stolen property, a fourth-degree

felony in violation of R.C. 2913.51(A). Doucette pleaded not guilty to the two charges.

{¶ 3} The State filed a bill of particulars in which it described the police officer’s pursuit

of a stolen vehicle driven by Doucette on May 13, 2025. According to the bill of particulars,

Doucette drove at a high speed through a school zone, the pursuit continued through several

streets reaching speeds of 80 mph, he “continued to drive recklessly driving the wrong way

on a south bound lane, sped through a construction zone with workers present, and

eventually crashed into a red Chevrolet Camero in an intersection.”

{¶ 4} On August 4, 2025, Doucette withdrew his not guilty plea and entered a plea of

guilty to one count of failure to comply with an order or signal of a police officer. The written

plea form signed by Doucette alerted him that he could receive up to a maximum prison

sentence of 60 months, up to a $10,000 fine, and a license suspension of 3 years to life.

The trial court reiterated the potential sentences during the plea hearing and stated that a

2 license suspension was mandatory. Following the plea colloquy, the trial court found him

guilty of failure to comply with an order or signal of a police officer and dismissed the one

count of receiving stolen property. The trial court ordered the preparation of a presentence

investigation (“PSI”) prior to sentencing.

{¶ 5} On August 19, 2025, the trial court held a sentencing hearing. The State asked

the trial court to impose the maximum sentence based on the dangerous pursuit caused by

Doucette’s actions and his extensive criminal history. Defense counsel presented his case

for the imposition of a lighter sentence, and Doucette expressed his remorse. The court

stated that it had considered the purposes of felony sentencing in R.C. 2929.11 and the

factors set forth in R.C. 2929.12, and it sentenced Doucette to 60 months in prison and

suspended his driver’s license for 25 years. Doucette was ordered to pay court costs, but

no fine was imposed. Doucette filed a timely notice of appeal.

II. The Trial Court’s Imposition of a 25-Year Driver’s License Suspension Is Not

Contrary to Law

{¶ 6} Doucette’s first assignment of error states:

THE TRIAL COURT ERRED BY IMPOSING A TWENTY-FIVE-YEAR

DRIVER’S LICENSE SUSPENSION WITHOUT ARTICULATING A

SUFFICIENT RATIONALE FOR SUCH AN EXTRAORDINARY

DISCRETIONARY SANCTION.

{¶ 7} In reviewing felony sentences, appellate courts must apply the standard of

review set forth in R.C. 2953.08(G)(2). State v. Marcum, 2016-Ohio-1002, ¶ 22. Under

this statute, an appellate court may increase, reduce, or otherwise modify a sentence, or it

may vacate the sentence and remand for resentencing, only if it “clearly and convincingly”

finds either: (1) that the record does not support certain specified findings or (2) that the

3 sentence imposed is otherwise contrary to law. R.C. 2953.08(G)(2). Doucette does not

identify any statutory findings that needed to be made prior to the trial court’s imposition of

a 25-year driver’s license suspension. Therefore, we limit our analysis to whether the

driver’s license suspension imposed by the trial court is clearly and convincingly contrary to

law. “A sentence is contrary to law when it falls outside the statutory range for the offense

or if the sentencing court does not consider R.C. 2929.11 and 2929.12.” State v. Bartley,

2023-Ohio-2325, ¶ 9 (2d Dist.), citing State v. Dorsey, 2021-Ohio-76, ¶ 18 (2d Dist.).

{¶ 8} Pursuant to R.C. 2921.331(E), the trial court was required to impose a class-

two driver’s license suspension within the range provided under R.C. 4510.02(A)(2) as part

of Doucette’s sentence for failure to comply with an order or signal of a police officer. The

authorized range for the mandatory license suspension is a definite period of three years to

life. R.C. 4510.02(A)(2). The 25-year driver’s license suspension imposed by the trial

court is within this authorized statutory range. Moreover, prior to imposing this suspension,

the trial court stated that it had considered the purposes and principles of sentencing set

forth in R.C. 2929.11, as well as the factors in R.C. 2929.12. “‘[A] sentence is not contrary

to law when the trial court imposes a sentence within the statutory range, after expressly

stating that it had considered the purposes and principles of sentencing set forth in R.C.

2929.11, as well as the factors in R.C. 2929.12.’” State v. Frazier, 2015-Ohio-344, ¶ 10

(2d Dist.), quoting State v. Rodeffer, 2013-Ohio-5759, ¶ 32 (2d Dist.).

{¶ 9} The first assignment of error is overruled.

III. Doucette’s Maximum Prison Sentence Is Not Contrary to Law

{¶ 10} Doucette’s second assignment of error states:

THE TRIAL COURT’S IMPOSITION OF A MAXIMUM PRISON TERM, WHEN

COUPLED WITH A 25-YEAR LICENSE SUSPENSION, WAS CONTRARY

4 TO R.C. 2929.11 MINIMUM SANCTIONS PRINCIPLE.

{¶ 11} R.C. 2929.11(A) provides, in relevant part: “The overriding purposes of felony

sentencing are to protect the public from future crime by the offender and others, to punish

the offender, and to promote the effective rehabilitation of the offender using the minimum

sanctions that the court determines accomplish those purposes without imposing an

unnecessary burden on state or local government resources.” (Emphasis added.)

Doucette concedes that the trial court was not required to make express findings or use

specific language when determining the minimum sanctions to accomplish the purposes of

felony sentencing. But Doucette contends that “the absence of any articulated reasoning

addressing the cumulative severity of the sanctions imposed demonstrates that the court did

not meaningfully apply R.C. 2929.11(A)’s ‘minimum sanctions’ principle.” Appellant’s Brief,

p. 12. Doucette states that he is not requesting us “to reweigh seriousness or recidivism

factors or to determine that a lesser prison term would have been preferable.” Id. at 13.

Rather, Doucette “asks only that the sentencing court be required to demonstrate, on the

record, that it applied the governing statutory directive to the full scope of punishment

imposed.” Id. at 13-14. Therefore, Doucette requests us to “remand for resentencing so

the trial court may exercise its discretion within the statutory framework and articulate its

reasoning accordingly.” Id. at 14.

{¶ 12} Doucette was convicted of a third-degree felony in violation of

R.C. 2921.331(B). He received a maximum prison sentence of 60 months, which is within

the authorized statutory range. R.C. 2929.14(A)(3)(a). At the sentencing hearing, the trial

court discussed much of Doucette’s lengthy criminal history. The court then stated that it

had considered the purposes and principles of sentencing set forth in R.C. 2929.11, as well

as the factors in R.C. 2929.12. The court noted that it had considered the minimum

5 sanctions that it could impose to accomplish the purposes of felony sentencing set forth in

R.C. 2929.11 without imposing an unnecessary burden on state or local government

resources. Although it was not required to explain why it imposed a maximum prison

sentence, the court stated:

The Court finds that based on all of these factors that this is the most serious

form of the offense. The Court finds that the Defendant has a history of

criminal convictions, and has not responded favorably to sanctions previously

imposed. And the Court finds the Defendant has previously been sent to

West Central, had multiple community control violations, and three prior prison

terms imposed. The Court finds the Defendant was on community control at

the time of the offense. His ORAS is high, a 27.

Sentencing Tr. 16.

{¶ 13} In its judgment entry, the trial court stated that it had reviewed the PSI prior to

sentencing, as well as the record, oral statements of counsel, the defendant’s statement,

the purposes and principles of sentencing set forth in R.C. 2929.11, and the factors set forth

in R.C. 2929.12. The court concluded that “this is the most serious form of the offense.”

{¶ 14} “The trial court has full discretion to impose any sentence within the authorized

statutory range, and the court is not required to make any findings or give its reasons for

imposing maximum or more than minimum sentences.” State v. King, 2013-Ohio-2021,

¶ 45 (2d Dist.), citing State v. Foster, 2006-Ohio-856, paragraph seven of the syllabus.

Therefore, “when making a felony sentencing decision, a trial court must consider the

R.C. 2929.11 purposes of felony sentencing and the R.C. 2929.12 felony sentencing factors,

but there is no requirement for the trial court to make any on-the-record findings regarding

R.C. 2929.11 and R.C. 2929.12.” State v. Benedict, 2021-Ohio-966, ¶ 8 (2d Dist.). “It is

6 enough that the record demonstrates that the trial court considered R.C. 2929.11 and

R.C. 2929.12 prior to imposing its sentence.” State v. Trent, 2021-Ohio-3698, ¶ 15

(2d Dist.). The record establishes that the trial court considered R.C. 2929.11 and 2929.12

before imposing its sentence. Doucette has failed to establish that his maximum prison

sentence is clearly and convincingly contrary to law. Therefore, there is no reason to

remand the matter to the trial court.

{¶ 15} The second assignment of error is overruled.

IV. Conclusion

{¶ 16} Having overruled the assignments of error, the judgment of the trial court is

affirmed.

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HUFFMAN, J., and HANSEMAN, J., concur.