Pa. Cons. Stat. » 18 Pa. Cons. Stat. (CRIMES AND OFFENSES) / Chapter 39
Pennsylvania Consolidated Statutes

18 Pa. Cons. Stat. § 3922 (2026)

 Theft by deception.

✓ current as of May 2026
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§ 3922.  Theft by deception.

(a)  Offense defined.--A person is guilty of theft if he intentionally obtains or withholds property of another by deception. A person deceives if he intentionally:

(1)  creates or reinforces a false impression, including false impressions as to law, value, intention or other state of mind; but deception as to a person's intention to perform a promise shall not be inferred from the fact alone that he did not subsequently perform the promise;

(2)  prevents another from acquiring information which would affect his judgment of a transaction; or

(3)  fails to correct a false impression which the deceiver previously created or reinforced, or which the deceiver knows to be influencing another to whom he stands in a fiduciary or confidential relationship.

(b)  Exception.--The term "deceive" does not, however, include falsity as to matters having no pecuniary significance, or puffing by statements unlikely to deceive ordinary persons in the group addressed.

 

Cross References.  Section 3922 is referred to in sections 3311, 5708 of this title; sections 5552, 9717 of Title 42 (Judiciary and Judicial Procedure).

Notes of Decisions
Cited in 232 cases (36 in the last 5 years), 1975–2026 · leading case: Commonwealth v. Wojdak, 466 A.2d 991 (Pa. 1983).
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Commonwealth v. Wojdak, 466 A.2d 991 (Pa. 1983). · cites it 8× “§ 3923, and attempted theft by deception, 18 Pa.C.S. § 3922. Under 18 Pa.C.S. § 3923, "[a] person is guilty of theft [by extortion] if he intentionally obtains or withholds property of another by threatening to: * * * (4) take or withhold action as an official or cause an…”
Com. v. Risoldi, C., 238 A.3d 434 (Pa. Super. Ct. 2020). · cites it 3× “18 Pa.C.S. § 3922(a). As Risoldi points out, she was paid approximately $7.”
Commonwealth v. Stetler, 95 A.3d 864 (Pa. Super. Ct. 2014). · cites it 5× “Count Jh Theft by Deception, 18 Pa.C.S. § 3922 and Count 5, Theft by Failure to Make Required Disposition of Funds Received, 18 Pa.”
Khaimraj Singh v. John Ashcroft, Attorney Gen. of the United States of Am., 383 F.3d 144 (3rd Cir. 2004). · cites it 2× “2 (quoting 18 Pa. Cons.Stat. § 3922(a) 9 ); Munroe, 353 F.”
Commonwealth v. Edwards, 582 A.2d 1078 (Pa. 1990). · cites it 8× “The Commonwealth has attached to each incident three theft-related labels: Theft by Deception (18 Pa.C.S. § 3922), Theft by Failure to Make Required Disposition (18 Pa.”
Commonwealth v. Littlehales, 915 A.2d 662 (Pa. Super. Ct. 2007). · cites it 4× “18 Pa.C.S. § 3922 (relating to theft by deception)—not less than 12 months, but the imposition of the minimum sentence shall be discretionary with the court where the court finds justifiable cause and that finding is written in the opinion.”
Joseph Curry v. Brianne Yachera, 835 F.3d 373 (3rd Cir. 2016). “Curry was charged with theft by deception, pursuant to 18 Pa. Cons. Stat. § 3922 (a)(1), a misdemeanor of the second degree.”
Commonwealth v. Adams, 177 A.3d 359 (Pa. Super. Ct. 2017). · cites it 2× “§ 4101(a)(3), 14 counts of theft by deception, 18 Pa.C.S. § 3922(a)(1), 14 counts of retail theft, 18 Pa.”
Commonwealth v. Wallace, 97 A.3d 310 (Pa. 2014). · cites it 3× “Chief Justice CASTILLE files a concurring opinion in which Justice EAKIN joins. Justice SAYLOR flies a concurring opinion.”
Commonwealth v. Veon, 150 A.3d 435 (Pa. 2016). “18 Pa.C.S. § 3922(a)(1). . 18 Pa.C.S. § 3927(a).”
Commonwealth v. Warner, 476 A.2d 341 (Pa. 1984). · cites it 6× “18 Pa.C.S. § 3922 (Theft by Deception) provides: § 3922.”
Commonwealth v. Gallo, 345 A.2d 747 (Pa. Super. Ct. 1975). · cites it 10× “, October 9, 1975: On July 2, 1974, appellant William Gallo was found guilty in a non-jury trial of theft by deception (18 Pa. C.S. § 3922). On November 21, 1974, appellant was sentenced to pay costs in the amount of $90.”
Show all 232 citing cases →
— 18 Pa. Cons. Stat. § 3922(8)(1) — 1 case
Com. v. Eakin, S. (Pa. Super. Ct. 2015).
— 18 Pa. Cons. Stat. § 3922(A)(1) — 3 cases
Com. v. Fulk, E. (Pa. Super. Ct. 2017).
Com. v. Adbullah-Talib, H. (Pa. Super. Ct. 2015).
Commonwealth v. Kidd, 11 Pa. D. & C.5th 551 (2010).
— 18 Pa. Cons. Stat. § 3922(a) — 30 cases
Com. v. Risoldi, C., 238 A.3d 434 (Pa. Super. Ct. 2020). “18 Pa.C.S. § 3922(a). As Risoldi points out, she was paid approximately $7.”
Khaimraj Singh v. John Ashcroft, Attorney Gen. of the United States of Am., 383 F.3d 144 (3rd Cir. 2004). “2 (quoting 18 Pa. Cons.Stat. § 3922(a) 9 ); Munroe, 353 F.”
Commonwealth v. Wojdak, 466 A.2d 991 (Pa. 1983). “§ 3923, and attempted theft by deception, 18 Pa.C.S. § 3922. Under 18 Pa.C.S. § 3923, "[a] person is guilty of theft [by extortion] if he intentionally obtains or withholds property of another by threatening to: * * * (4) take or withhold action as an official or cause an…”
Jan Knapik v. John Ashcroft, Attorney Gen. of the United States, 384 F.3d 84 (3rd Cir. 2004).
Commonwealth v. Karetny, 880 A.2d 505 (Pa. 2005).
— 18 Pa. Cons. Stat. § 3922(a)(1) — 94 cases
Commonwealth v. Adams, 177 A.3d 359 (Pa. Super. Ct. 2017). “§ 4101(a)(3), 14 counts of theft by deception, 18 Pa.C.S. § 3922(a)(1), 14 counts of retail theft, 18 Pa.”
Commonwealth v. Veon, 150 A.3d 435 (Pa. 2016). “18 Pa.C.S. § 3922(a)(1). . 18 Pa.C.S. § 3927(a).”
Com. v. Risoldi, C., 238 A.3d 434 (Pa. Super. Ct. 2020). “18 Pa.C.S. § 3922(a). As Risoldi points out, she was paid approximately $7.”
Commonwealth v. Rush, 909 A.2d 805 (Pa. Super. Ct. 2006).
Commonwealth v. Succi, 173 A.3d 269 (Pa. Super. Ct. 2017).
— 18 Pa. Cons. Stat. § 3922(a)(2) — 2 cases
Com. v. Picone, A. (Pa. Super. Ct. 2018).
Com. v. Rivera, E. (Pa. Super. Ct. 2024).
— 18 Pa. Cons. Stat. § 3922(a)(3) — 6 cases
Krystal Jeep Eagle, Inc. v. Bureau of Prof'l & Occupational Affairs, 725 A.2d 846 (Pa. Commw. Ct. 1999).
A. Turay, F.D. v. BPOA, State Bd. of Funeral Directors (Pa. Commw. Ct. 2017).
Com. v. Picone, A. (Pa. Super. Ct. 2018).
Com. v. Addleman, T. (Pa. Super. Ct. 2019).
Com. v. Cook, J. (Pa. Super. Ct. 2025).
— 18 Pa. Cons. Stat. § 3922(a)(l) — 10 cases
Commonwealth v. Snyder, 483 A.2d 933 (Pa. 1984).
Commonwealth v. Wehr, 9 Pa. D. & C.5th 434 (2009).
Commonwealth v. DiNatale, 23 Pa. D. & C.5th 428 (2011).
Com. v. Davis, B. (Pa. Super. Ct. 2016).
Com. v. Tarapchak, S. (Pa. Super. Ct. 2020).
— 18 Pa. Cons. Stat. § 3922(b) — 4 cases
State v. Roberts, 711 P.2d 235 (Utah 1985).
Commonwealth v. Joy, 384 A.2d 1288 (Pa. Super. Ct. 1978).
Commonwealth v. Donahue, B., Aplt. (Pa. 2022).
Com. v. Henck, A., 2025 Pa. Super. 158 (Pa. Super. Ct. 2025).
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