it reflects the ‘plain meaning.’ ” Ariz. Citizens Clean Elections Comm’n v. Brain, 234 Ariz. 322, 329, ¶ 34, 322 P.3d 139, 146 (2014) (Bales, J., dissenting). ¶ 17 Second, the dissent asserts this court has “previously recognized that A.R.S. § 13-2508 is a victim-directed crime.” See infra ¶ 29. The cases the dissent cites in support of this conclusion did not, however, address the double jeopardy issue presented here. See State v. Mitchell, 204 Ariz. 216, 62 P.3d 616 (App.2003) (discussing meaning of “effecting an arrest”); State v. Sarkhabi, 202 Ariz. 450, 46 P.3d 1071 (App.2002) (discussing necessity of physical act being directed towards a police officer and rejecting argument that resisting arrest is “victimless crime”); State v. Womack, 174 Ariz. 108, 847 P.2d 609 (App.1992) (<HOLDING>). ¶ 18 Third, to be sure, as the dissent notes,
holding that force exerted against an officer after an arrest is complete cannot be used as the basis for prosecuting one for resisting arrest holding avoiding arrest is not the same as resisting arrest holding that it is equally wellestablished that a suspects mere flight to escape arrest does not violate the resisting arrest statute holding that resisting arrest is lesser offense of assault on an officer holding that physical activity which prevents or delays an arrest including going limp is enough to sustain a conviction for resisting arrest under ohio law