Code of Alabama
Ala. Code § 15-18-66 (2026)
Definitions.
✓ official Alabama Legislature (ALISON) text, current July 2026
As used in this article, the following words and terms shall have the meanings respectively ascribed by this section:
(1) CRIMINAL ACTIVITIES. Any offense with respect to which the defendant is convicted or any other criminal conduct admitted by the defendant.
(2) PECUNIARY DAMAGES. All special damages which a person shall recover against the defendant in a civil action arising out of the facts or events constituting the defendant’s criminal activities; the term shall include, but not be limited to the money or other equivalent of property taken, broken, destroyed, or otherwise used or harmed and losses such as travel, medical, dental or burial expenses and wages including but not limited to wages lost as a result of court appearances.
(3) RESTITUTION. Full, partial or nominal payment of pecuniary damages to the victim or to its equivalent in services performed or work or labor done for the benefit of the victim as determined by the court of record.
(4) VICTIM. Any person whom the court determines has suffered a direct or indirect pecuniary damage as a result of the defendant’s criminal activities. “Victim” shall not include any participant in the defendant’s criminal activities.
(Acts 1980, No. 80-588, p. 928, §2.)
Notes of Decisions
Cited in 32
cases (2 in the last 5 years), 1986–2025 · leading case: Best v. State, 895 So. 2d 1050 (Ala. Crim. App. 2004).
Best v. State, 895 So. 2d 1050 (Ala. Crim. App. 2004). “In our opinion reversing the trial court's restitution award, this Court stated: "The term `criminal activities' is defined in § 15-18-66, Ala.Code 1975, as `[a]ny offense with respect to which the defendant is convicted or any other criminal conduct admitted by the defendant.”
Theodorou v. State, 53 So. 3d 151 (Ala. 2010). “” Section 15-18-66(2), Ala.Code 1975, defines “pecuniary damages” as “[a]ll special damages which a person shall recover against the defendant in a civil action arising out of the facts or events constituting the defendant’s criminal activities; the term shall include, but not…”
Butler v. State, 608 So. 2d 773 (Ala. Crim. App. 1992). “I would remand this case to the trial court for an evidentiary hearing to identify those beneficiaries and the specific pecuniary damages, as that term is defined by Ala.Code 1975, § 15-18-66, that those particular individuals suffered.”
Strough v. State, 501 So. 2d 488 (Ala. Crim. App. 1986). “§ 15-18-66(2), Code of Alabama 1975. Remuneration to Mr.”
Harris v. State, 542 So. 2d 1312 (Ala. Crim. App. 1989). “" Alabama Code 1975, § 15-18-66(4). Clearly, Ms.”
Ex Parte Fletcher, 849 So. 2d 900 (Ala. 2001). “) The ARVCA defines the term "pecuniary damages," at § 15-18-66(2): "All special damages which a person shall recover against the defendant in a civil action arising out of the facts or events constituting the defendant's criminal activities; the term shall include, but not be…”
State v. McMann, 541 N.W.2d 418 (Neb. Ct. App. 1995). “See, Ala. Code § 15-18-66 (1995) (defining restitution to include services performed or work or labor done for benefit of victim); Conn.”
Commonwealth v. Burwell, 58 A.3d 790 (Pa. Super. Ct. 2012). “See Alabama (Ala.Code § 15-18-66); Arizona (Ariz.Rev.Stat.”
Lamar v. State, 803 So. 2d 576 (Ala. Crim. App. 2001). “) The term “criminal activities” is defined in § 15-18-66, Ala.Code 1975, as “[a]ny offense with respect to which the defendant is convicted or any other criminal conduct admitted by the defendant.”
Holderfield v. State, 255 So. 3d 746 (Ala. Crim. App. 2017). “" § 15-18-66, Ala. Code 1975. Additionally, before a court may award restitution, the State must establish that the defendant's criminal activity was the proximate cause of the victim's pecuniary loss, damage, or injury.”
Moore v. State, 706 So. 2d 265 (Ala. Crim. App. 1997). “"Section 15-18-66(2), Code of Alabama 1975, provides that a victim may recover from a convicted defendant all special damages which a person could recover in a civil suit.”
W.D.J. v. State, 785 So. 2d 390 (Ala. 2000). “§ 15-18-66, Ala.Code 1975. This analysis, even without more, requires reversal of the restitution order.”
— Ala. Code § 15-18-66(1) — 7 cases
Best v. State, 895 So. 2d 1050 (Ala. Crim. App. 2004). “In our opinion reversing the trial court's restitution award, this Court stated: "The term `criminal activities' is defined in § 15-18-66, Ala.Code 1975, as `[a]ny offense with respect to which the defendant is convicted or any other criminal conduct admitted by the defendant.”
Reeves v. State, 24 So. 3d 549 (Ala. Crim. App. 2009).
B.M.J. v. State, 952 So. 2d 1174 (Ala. Crim. App. 2006).
Jones v. State, 71 So. 3d 36 (Ala. Crim. App. 2009).
BMJ v. State, 952 So. 2d 1174 (Ala. Crim. App. 2006).
— Ala. Code § 15-18-66(2) — 12 cases
Strough v. State, 501 So. 2d 488 (Ala. Crim. App. 1986). “§ 15-18-66(2), Code of Alabama 1975. Remuneration to Mr.”
Moore v. State, 706 So. 2d 265 (Ala. Crim. App. 1997). “"Section 15-18-66(2), Code of Alabama 1975, provides that a victim may recover from a convicted defendant all special damages which a person could recover in a civil suit.”
Theodorou v. State, 53 So. 3d 151 (Ala. 2010). “” Section 15-18-66(2), Ala.Code 1975, defines “pecuniary damages” as “[a]ll special damages which a person shall recover against the defendant in a civil action arising out of the facts or events constituting the defendant’s criminal activities; the term shall include, but not…”
Butler v. State, 608 So. 2d 773 (Ala. Crim. App. 1992). “I would remand this case to the trial court for an evidentiary hearing to identify those beneficiaries and the specific pecuniary damages, as that term is defined by Ala.Code 1975, § 15-18-66, that those particular individuals suffered.”
Ex Parte Fletcher, 849 So. 2d 900 (Ala. 2001). “) The ARVCA defines the term "pecuniary damages," at § 15-18-66(2): "All special damages which a person shall recover against the defendant in a civil action arising out of the facts or events constituting the defendant's criminal activities; the term shall include, but not be…”
— Ala. Code § 15-18-66(3) — 3 cases
Ex Parte Fletcher, 849 So. 2d 900 (Ala. 2001). “) The ARVCA defines the term "pecuniary damages," at § 15-18-66(2): "All special damages which a person shall recover against the defendant in a civil action arising out of the facts or events constituting the defendant's criminal activities; the term shall include, but not be…”
D.J.W. v. State, 705 So. 2d 521 (Ala. Crim. App. 1996).
DJW v. State, 705 So. 2d 521 (Ala. Crim. App. 1997).
— Ala. Code § 15-18-66(4) — 8 cases
Theodorou v. State, 53 So. 3d 151 (Ala. 2010). “” Section 15-18-66(2), Ala.Code 1975, defines “pecuniary damages” as “[a]ll special damages which a person shall recover against the defendant in a civil action arising out of the facts or events constituting the defendant’s criminal activities; the term shall include, but not…”
Harris v. State, 542 So. 2d 1312 (Ala. Crim. App. 1989). “" Alabama Code 1975, § 15-18-66(4). Clearly, Ms.”
Strough v. State, 501 So. 2d 488 (Ala. Crim. App. 1986). “§ 15-18-66(2), Code of Alabama 1975. Remuneration to Mr.”
Butler v. State, 608 So. 2d 773 (Ala. Crim. App. 1992). “I would remand this case to the trial court for an evidentiary hearing to identify those beneficiaries and the specific pecuniary damages, as that term is defined by Ala.Code 1975, § 15-18-66, that those particular individuals suffered.”
W.D.J. v. State, 785 So. 2d 385 (Ala. Crim. App. 1998).
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