Demers v. State
In Demers v. State, 42 P.3d 1 (Alaska App. 2002), the Court addressed a different aspect of this restitution problem: whether a defendant could be ordered to pay restitution for the value of non-monetary donations (donations of goods and services) made by members of the community to offset or ameliorate the victim's loss.
To the extent that such nonmonetary donations reduce the expenses that the victim would otherwise have to bear, these contributions from members of the community might reasonably be considered part of the total social cost of the defendant's crime.
Nevertheless, the Court concluded that Alaska's restitution statutes do not authorize a sentencing court to order a defendant to reimburse the value of these non-monetary contributions. (See 42 P.2d at 2. - 13 - 1812.)