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173 46-18-201 77 46-18-202 154 46-18-203 10 46-18-204 4 46-18-205 1 46-18-211 46-18-212 1 46-18-213 3 46-18-219 1 46-18-220 21 46-18-221 32 46-18-222 5 46-18-223 46-18-224 16 46-18-225 33 46-18-231 42 46-18-232 1 46-18-233 5 46-18-234 2 46-18-235 24 46-18-236 3 46-18-237 51 46-18-241 30 46-18-242 59 46-18-243 27 46-18-244 2 46-18-245 21 46-18-246 5 46-18-247 1 46-18-248 8 46-18-249 2 46-18-250 3 46-18-251 7 46-18-255 1 46-18-256 46-18-261

Mont. Code Ann. § 46-18-243

(2001)

Definitions

For purposes of 46-18-241 through 46-18-249, the following definitions apply:

(1) "Pecuniary loss" means:

(a) all special damages, but not general damages, substantiated by evidence in the record, that a person could recover against the offender in a civil action arising out of the facts or events constituting the offender's criminal activities, including without limitation the money equivalent of loss resulting from property taken, destroyed, broken, or otherwise harmed and out-of-pocket losses, such as medical expenses, loss of income, expenses reasonably incurred in obtaining ordinary and necessary services that the victim would have performed if not injured, expenses reasonably incurred in attending court proceedings related to the commission of the offense, and reasonable expenses related to funeral and burial or crematory services; and

(b) reasonable out-of-pocket expenses incurred by the victim in filing charges or in cooperating in the investigation and prosecution of the offense.

(2) (a) "Victim" means:

(i) a person who suffers loss of property, bodily injury, or death as a result of:

(A) the commission of an offense;

(B) the good faith effort to prevent the commission of an offense; or

(C) the good faith effort to apprehend a person reasonably suspected of committing an offense;

(ii) the estate of a deceased or incapacitated victim or a member of the immediate family of a homicide victim;

(iii) a governmental entity that suffers loss of property as a result of the commission of an offense in this state or that incurs costs or losses during the commission or investigation of an escape, as defined in 45-7-306, or during the apprehension or attempted apprehension of the escapee; or

(iv) an insurer or surety with a right of subrogation to the extent it has reimbursed the victim of the offense for pecuniary loss.

(b) Victim does not include a person who is accountable for the crime or accountable for a crime arising from the same transaction.

Opinions construing this section

59 opinions
2026 MT 180N Aug 4, 2026 Affirmed
State v. Richards
Majority by Beth Baker · 4 to 1
’s admitted or proven criminal conduct as substantiated by evidence in the record. State v. Simpson, 2014 MT 175, ¶ 14, 375 Mont. 393, 328 P.3d 1144 (citing § 46-18-243, MCA; State v. Breeding, 2008 MT 162, ¶ 19, 343 Mont. 323, 184 P.3d 313). Relevant here, § 46-18-243(1), MCA, defines “pecuniary loss” as: 8 (a) all speci
2026 MT 180N Aug 4, 2026 Affirmed
State v. Richards
Dissenting by Laurie McKinnon · 4 to 1
ment; and (d) reasonable out-of-pocket expenses incurred by the victim in filing charges or in cooperating in the investigation and prosecution of the offense. Section 46-18-243(1), MCA. The District Court did not indicate whether it was awarding damages under subsection (1)(a) or (1)(b), or both. Subsections (1)(a) and (1)(b) are the only pro
2026 MT 74N Apr 7, 2026 Affirmed
City of Helena v. Ittner
Majority by Katherine M. Bidegaray · 5 to 0
tation was not required. McClelland, ¶ 10; Simpson, ¶ 14. ¶18 Ittner also argues that the $600 lost wages award was unsubstantiated and inflated. However, § 46-18-243(1)(a), MCA, expressly includes “loss of income” and expenses reasonably incurred in attending court proceedings related to the offense. Thus, time reasonably spent at
2025 MT 282 Dec 9, 2025 Affirmed
State v. K. Mullendore
Majority by Laurie McKinnon · 5 to 0
sustained pecuniary loss, including a person suffering an economic loss.” “Victim” includes “a member of the immediate family of a homicide victim.” Section 46-18-243(2)(a)(ii), MCA. “Pecuniary loss” includes, in relevant part: (a) all special damages, but not general damages, substantiated by evidence in the record, that a person coul
2025 MT 218 Sep 30, 2025 Reversed
State v. Powell
Majority by Katherine M Bidegaray · 4 to 1 with 1 concurring
offender’s inmate account “and use the money to satisfy any existing restitution 7 See § 46-18-242, MCA (investigation and report of victim’s losses); § 46-18-243, MCA (defining “victim” and “pecuniary loss”). 9 obligation.” Section 46-18-244(6)(a), MCA; see also § 46-18-244(6)(b), MCA (requiring offender to au
Official Annotations archive.org, 2001 edition
History:
En. Sec. 3, Ch. 426, L. 1983
Amd. Sec. 15, Ch. 125, L. 1995
Amd. Sec. 2, Ch. 26, L. 1997