Lamar v. State, 803 So.2d 576 (Ala. Crim. App. 2001)

Cases | Lamar v. State, 803 So.2d 576 (Ala. Crim. App. 2001) | 2018

The defendant pled guilty to leaving the scene of an accident and was ordered to pay restitution. The defendant appealed the restitution order on the basis that the victim’s injuries were proximately caused by the accident, rather than by the defendant’s leaving the scene. The appellate court held that the trial court had no statutory authorization to order the defendant to pay restitution for injuries sustained during the accident. The defendant did not admit to conduct that could be said to proximately cause the injuries. The crime of “leaving the scene” does not require that the defendant cause the accident.