Code of Alabama
Ala. Code § 13A-8-43 (2026)
Robbery in the Third Degree.
✓ official Alabama Legislature (ALISON) text, current July 2026
(a) A person commits the crime of robbery in the third degree if in the course of committing a theft he:
(1) Uses force against the person of the owner or any person present with intent to overcome his physical resistance or physical power of resistance; or
(2) Threatens the imminent use of force against the person of the owner or any person present with intent to compel acquiescence to the taking of or escaping with the property.
(b) Robbery in the third degree is a Class C felony.
(Acts 1977, No. 607, p. 812, §3307.)
Notes of Decisions
Cited in 140
cases (8 in the last 5 years), 1982–2026 · leading case: Lucas v. State, 45 So. 3d 380 (Ala. Crim. App. 2009).
Lucas v. State, 45 So. 3d 380 (Ala. Crim. App. 2009). “357 pistol during the robbery and displayed it to the victim, in explaining that threatening the use of a deadly weapon is sufficient proof of the use of force to prove that element under Ala.”
United States v. Terrance Tyrone Davis, 875 F.3d 592 (11th Cir. 2017). “The presentence investigation report determined that he was an armed career criminal based on three earlier convictions: (1) a 1998 conviction for third degree robbery, in violation of Alabama Code § 13A-8-43; (2) a 2003 conviction for second degree assault, in violation of…”
Holt v. State, 960 So. 2d 726 (Ala. Crim. App. 2006). “Robbery in the first degree requires that the accused either use force or threaten the imminent use of force, see § 13A-8-43, Ala.Code 1975, and that the accused either "cause[ ] serious physical injury to another," § 13A-8-41(a)(2), or be "armed with a deadly weapon or…”
United States v. Pedro Santiesteban-Hernandez, 469 F.3d 376 (5th Cir. 2006). “, Ala. Code § 13A-8-43(a) (West 2003); Wis.”
State v. Owens, 20 S.W.3d 634 (Tenn. 2000). “Stat. Ann. § 515.030 (Michie 1999); Me.Rev.”
Shaw v. State, 207 So. 3d 79 (Ala. Crim. App. 2014). “Robbery in the third degree, by its statutory definition in § 13A-8-43, AIa.Code 1975, involves the use or threat of force.”
Revis v. State, 101 So. 3d 247 (Ala. Crim. App. 2011). “Code 1975, states that “[a] person commits the crime of robbery in the first degree if he violates Section 13A-8-43 and he ... [i]s armed with a deadly weapon or dangerous instrument; or .”
Childers v. State, 899 So. 2d 1025 (Ala. 2004). “" [2] Section 13A-8-42 provides: "(a) A person commits the crime of robbery in the second degree if he violates Section 13A-8-43 and he is aided by another person actually present." [3] At the time of Anderson's indictment, § 13A-6-61(a)(1) provided: "(a) A male commits the…”
Lee v. State, 898 So. 2d 790 (Ala. Crim. App. 2003). “"A person commits the crime of robbery in the first degree if he violates Section 13A-8-43 and he: "(1) Is armed with a deadly weapon or dangerous instrument; or "(2) Causes serious physical injury to another.”
Whitt v. State, 827 So. 2d 869 (Ala. Crim. App. 2001). “First-degree robbery is defined by § 13A-8-41(a), which, in pertinent part, provides: "A person commits the crime of robbery in the first degree if he violates section 13A-8-43 and he: "(1) Is armed with a deadly weapon or dangerous instrument.”
United States v. Lusion Yoshua Rice, 941 F.3d 1259 (11th Cir. 2019). “Ala. Code § 13A-8-43. Second-degree robbery requires the same elements as third- degree robbery, plus aid by another person actually present.”
Wilson v. State, 142 So. 3d 732 (Ala. Crim. App. 2010). “Code 1975, provides: “A person commits the crime of robbery in the third degree if in the course of committing a theft he: “(1) Uses force against the person of the owner or any person present with intent to overcome his physical resistance or physical power of resistance; or…”
— Ala. Code § 13A-8-43(1) — 1 case
Wilson v. State, 695 So. 2d 195 (Ala. Crim. App. 1996).
— Ala. Code § 13A-8-43(a) — 22 cases
United States v. Pedro Santiesteban-Hernandez, 469 F.3d 376 (5th Cir. 2006). “, Ala. Code § 13A-8-43(a) (West 2003); Wis.”
Whitt v. State, 827 So. 2d 869 (Ala. Crim. App. 2001). “First-degree robbery is defined by § 13A-8-41(a), which, in pertinent part, provides: "A person commits the crime of robbery in the first degree if he violates section 13A-8-43 and he: "(1) Is armed with a deadly weapon or dangerous instrument.”
United States v. Donnie Walton, 881 F.3d 768 (9th Cir. 2018).
Lee v. State, 898 So. 2d 790 (Ala. Crim. App. 2003). “"A person commits the crime of robbery in the first degree if he violates Section 13A-8-43 and he: "(1) Is armed with a deadly weapon or dangerous instrument; or "(2) Causes serious physical injury to another.”
Wilson v. State, 142 So. 3d 732 (Ala. Crim. App. 2010). “Code 1975, provides: “A person commits the crime of robbery in the third degree if in the course of committing a theft he: “(1) Uses force against the person of the owner or any person present with intent to overcome his physical resistance or physical power of resistance; or…”
— Ala. Code § 13A-8-43(a)(1) — 4 cases
Lewis v. State, 469 So. 2d 1291 (Ala. Crim. App. 1984).
Shaw v. State, 207 So. 3d 79 (Ala. Crim. App. 2014). “Robbery in the third degree, by its statutory definition in § 13A-8-43, AIa.Code 1975, involves the use or threat of force.”
Ingram v. State, 878 So. 2d 1208 (Ala. Crim. App. 2003).
Harris v. State, 512 So. 2d 129 (Ala. Crim. App. 1987).
— Ala. Code § 13A-8-43(a)(2) — 12 cases
Lewis v. State, 469 So. 2d 1291 (Ala. Crim. App. 1984).
Ex Parte Verzone, 868 So. 2d 399 (Ala. 2003).
Franklin v. State, 854 So. 2d 153 (Ala. Crim. App. 2003).
Ex parte Willie Conner., 165 So. 3d 556 (Ala. 2014).
Hays v. State, 518 So. 2d 749 (Ala. Crim. App. 1985).
— Ala. Code § 13A-8-43(a)(l) — 4 cases
Shaw v. State, 207 So. 3d 79 (Ala. Crim. App. 2014). “Robbery in the third degree, by its statutory definition in § 13A-8-43, AIa.Code 1975, involves the use or threat of force.”
Jackson v. State, 969 So. 2d 930 (Ala. Crim. App. 2007).
Harris v. State, 512 So. 2d 129 (Ala. Crim. App. 1987).
Otey v. State, 474 So. 2d 112 (Ala. Crim. App. 1984).
— Ala. Code § 13A-8-43(b) — 2 cases
Adams v. State, 825 So. 2d 239 (Ala. Crim. App. 2001).
Myers v. State, 715 So. 2d 928 (Ala. Crim. App. 1998).
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