Code of Alabama
Ala. Code § 13A-12-203 (2026)
Attempt to Commit Controlled Substance Crime.
✓ official Alabama Legislature (ALISON) text, current July 2026
(a) A person is guilty of an attempt to commit a controlled substance crime if he engages in the conduct defined in Section 13A-4-2(a), and the crime attempted is a controlled substance crime.
(b) The principles of liability and defenses for an attempt to commit a controlled substance crime are the same as those specified in Sections 13A-4-2(b) through (c), and in Section 13A-4-5.
(c) An attempt to commit a controlled substance crime shall be punished the same as the controlled substance crime attempted.
(Acts 1987, No. 87-612, p. 1061, §3; Code 1975, §20-2-162; Acts 1988, 1st Ex. Sess., No. 88-918, p. 512, §2(8).)
Notes of Decisions
Cited in 14
cases, 1990–2020 · leading case: Hulsey v. State, 196 So. 3d 342 (Ala. Crim. App. 2015).
Hulsey v. State, 196 So. 3d 342 (Ala. Crim. App. 2015). “Code 1975, attempt to commit a controlled-substance crime, see § 13A-12-203, Ala.Code 1975, and reckless endangerment, see § 13A-6-24, Ala.”
Skinner v. State, 843 So. 2d 820 (Ala. Crim. App. 2002). “Code 1975, and an additional five years' imprisonment pursuant to § 13A-12-270, Ala.”
Harris v. State, 580 So. 2d 33 (Ala. Crim. App. 1990). “The indictment charged the appellant with attempting to traffic in cocaine as follows: "The Grand Jury of said County charge that before the finding of this Indictment, ROBERT EARL HARRIS, alias ROBERT E.”
Rowell v. State, 666 So. 2d 825 (Ala. Crim. App. 1993). “1991); attempt to commit a controlled substance crime, Ala. Code 1975, § 13A-12-203; and unlawful possession of marijuana in the first degree (possession *829 for other than personal use), § 13A-12-213(a)(1), may all involve "possession with intent to sell.”
Rhodes v. State, 686 So. 2d 1288 (Ala. Crim. App. 1996). “The appellant, Troy Ray Rhodes, pleaded guilty to attempted possession of a controlled substance (cocaine), a violation of § 13A-12-203, Code of Alabama 1975. He was sentenced to 10 years in the state penitentiary.”
Wallace v. State, 130 So. 3d 212 (Ala. Crim. App. 2013). “A reasonable jury could not have concluded beyond a reasonable doubt that Wallace was guilty of completed crime of the unlawful manufacture of methamphetamine, and I dissent from the majority’s holding to the contrary.”
Williams v. State, 961 So. 2d 929 (Ala. Crim. App. 2006). “tment alleged that the appellant *931 "did with the intent to commit the crime of Unlawful Possession or Receipt of a Controlled Substance, in violation of Section 13A-12-212, knowingly and unlawfully attempt to obtain Hydrocodone, a controlled substance, by fraud, deceit,…”
May v. State, 729 So. 2d 362 (Ala. Crim. App. 1998). “May, pled guilty to three counts of attempted unlawful possession of a controlled substance, a violation of § 13A-12-203 and § 13A-12-212, Ala.Code 1975.”
Lynch v. State, 640 So. 2d 44 (Ala. Crim. App. 1993). “Section 13A-12-203(e) mandates that “[a]n attempt to commit a controlled substance crime shall be punished the same as the controlled substance crime attempted.”
Ex Parte Colbert, 615 So. 2d 1218 (Ala. 1992). “Section 13A-12-203(a) provides: "(a) A person is guilty of an attempt to commit a controlled substance crime if he engages in the conduct defined in section 13A-4-2(a) [which states that `[a] person is guilty of an attempt to commit a crime if, with the intent to commit a…”
Harris v. State, 274 So. 3d 304 (Ala. Crim. App. 2018). “Holman Correctional Facility to deliver cocaine to inmates confined in said facility, in violation of § 13A-4-2, § 13A-12-203, and § 13-12-211 of the Code of Alabama.”
Harris v. State, 274 So. 3d 304 (Ala. Crim. App. 2018). “Holman Correctional Facility to deliver cocaine to inmates confined in said facility, in violation of § 13A-4-2, § 13A-12-203, and § 13-12-211 of the Code of Alabama.”
— Ala. Code § 13A-12-203(a) — 3 cases
Wallace v. State, 130 So. 3d 212 (Ala. Crim. App. 2013). “A reasonable jury could not have concluded beyond a reasonable doubt that Wallace was guilty of completed crime of the unlawful manufacture of methamphetamine, and I dissent from the majority’s holding to the contrary.”
Williams v. State, 961 So. 2d 929 (Ala. Crim. App. 2006). “tment alleged that the appellant *931 "did with the intent to commit the crime of Unlawful Possession or Receipt of a Controlled Substance, in violation of Section 13A-12-212, knowingly and unlawfully attempt to obtain Hydrocodone, a controlled substance, by fraud, deceit,…”
Ex Parte Colbert, 615 So. 2d 1218 (Ala. 1992). “Section 13A-12-203(a) provides: "(a) A person is guilty of an attempt to commit a controlled substance crime if he engages in the conduct defined in section 13A-4-2(a) [which states that `[a] person is guilty of an attempt to commit a crime if, with the intent to commit a…”
— Ala. Code § 13A-12-203(c) — 2 cases
Skinner v. State, 843 So. 2d 820 (Ala. Crim. App. 2002). “Code 1975, and an additional five years' imprisonment pursuant to § 13A-12-270, Ala.”
Parmley v. Estes (N.D. Ala. 2020).
— Ala. Code § 13A-12-203(e) — 1 case
Lynch v. State, 640 So. 2d 44 (Ala. Crim. App. 1993). “Section 13A-12-203(e) mandates that “[a]n attempt to commit a controlled substance crime shall be punished the same as the controlled substance crime attempted.”
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