Pennsylvania Consolidated Statutes

18 Pa. Cons. Stat. § 4108 (2026)

Commercial bribery and breach of duty to act disinterestedly.

✓ current as of May 2026

Coverage note: this corpus holds the consolidated Pa.C.S. titles only. Unconsolidated P.S. statutes (UTPCPL 73 P.S. § 201-1, Liquor Code, wage payment laws) are not included; a miss here does not mean the statute does not exist. Check palegis.us.

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§ 4108. Commercial bribery and breach of duty to act disinterestedly.

(a) Corrupt employee, agent or fiduciary.--An employee, agent or fiduciary commits a misdemeanor of the second degree when, without the consent of his employer or principal, he solicits, accepts, or agrees to accept any benefit from another person upon agreement or understanding that such benefit will influence his conduct in relation to the affairs of his employer or principal.

(b) Corrupt disinterested person.--A person who holds himself out to the public as being engaged in the business of making disinterested selection, appraisal, or criticism of commodities or services commits a misdemeanor of the second degree if he solicits, accepts or agrees to accept any benefit to influence his selection, appraisal or criticism.

(c) Solicitation.--A person commits a misdemeanor of the second degree if he confers, or offers or agrees to confer, any benefit the acceptance of which would be criminal under subsections (a) or (b) of this section.

Cross References. Section 4108 is referred to in sections 911, 5708 of this title; section 5552 of Title 42 (Judiciary and Judicial Procedure).

Notes of Decisions

Cited in 17 cases (2 in the last 5 years), 1977–2023 · leading case: Temple Univ. v. Salla Bros., Inc., 656 F. Supp. 97 (E.D. Pa. 1986).

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Temple Univ. v. Salla Bros., Inc., 656 F. Supp. 97 (E.D. Pa. 1986). · cites it 16× “§ 1952 (the Travel Act), and 18 Pa.C.S. § 4108 (commercial bribery) with particularity in accordance with Fed.”

Brokerage Concepts v. US Healthcare Inc (Part II), 140 F.3d 494 (3rd Cir. 1998). · cites it 2× “§ 1951 ; (2) violation of Pennsylvania’s commercial bribery statute, 18 Pa. Cons.Stat. § 4108(b); (3) mail fraud, 18 U.”

United States v. Louis Parise, Jr., 159 F.3d 790 (3rd Cir. 1998). · cites it 2× “21, § 380; Pennsylvania, see 18 Pa. Cons.Stat. Ann. § 4108; Rhode Island, see R.”

Brimmeier v. Pennsylvania Tpk. Comm'n, 147 A.3d 954 (Pa. Commw. Ct. 2016). “§ 911(b)(4) (conspiracy to commit corruption under Section 911 of the Crimes Code) (FI) Count 3—-Section 4108(b)—18 Pa.C.S. § 4108(b) (corruption by a disinterested person) (M2) Count 5—Section 901(a), 18 Pa.”

Commonwealth v. Bellis, 380 A.2d 1258 (Pa. Super. Ct. 1977). “872, § 667 (1939) (current version at 18 Pa.C.S. § 4108 (1973)). It is apparent from a reading of this section that the statute describes two crimes: one by the offeror of the bribe, and one by its taker.”

United States v. Johns, 742 F. Supp. 196 (E.D. Pa. 1990). “asions, Johns did use and cause to be used a facility in interstate commerce, with intent to distribute the proceeds of an unlawful activity and otherwise promote, manage, establish, carry on and facilitate the promotion, management, establishment and carrying on, of an unlawful…”

Commonwealth v. Bobitski, 632 A.2d 1294 (Pa. 1993). “As a result of this conduct the defendant was charged with five counts of commercial bribery, 18 Pa. C.S. § 4108(a), one count of forgery, 18 Pa.”

Westlake Plastic Co. v. O'Donnell, 182 F.R.D. 165 (E.D. Pa. 1998). · cites it 2× “Accordingly, Westlake’s allegation that O’Donnell engaged in commercial bribery in violation of 18 Pa.C.S. § 4108 also constitutes a predicate act for purposes of its civil RICO claim.”

In Re the Extradition of Chan Seong-I, 346 F. Supp. 2d 1149 (D.N.M. 2004). “1-12-08 (felony); 18 Pa. Cons.Stat. § 4108 (misdemeanor degree); R.”

United States v. Harder, 168 F. Supp. 3d 732 (E.D. Pa. 2016). · cites it 2× “”); 18 Pa. Cons. Stat. § 4108 ; 18 Pa. Cons. Stat.”

United States v. Johns, 688 F. Supp. 1017 (E.D. Pa. 1988). “The Travel Act charges are based on violations of the Pennsylvania Commercial Bribery statute, 18 Pa. Cons. Stat. Ann. § 4108. 3 . 18 U.”

Yeager's Fuel, Inc. v. Pennsylvania Power & Light Co., 804 F. Supp. 700 (E.D. Pa. 1992). “Attempting to satisfy this requirement, plaintiffs aver in their amended complaint that PP & L has on at least two occasions violated the Pennsylvania Commercial Bribery statute, 18 Pa.Cons.Stat. Ann. § 4108(a) (Purdon 1983), which states: Corrupt employee, agent or fiduciary.”

Show all 17 citing cases →

— 18 Pa. Cons. Stat. § 4108(a) — 8 cases

Temple Univ. v. Salla Bros., Inc., 656 F. Supp. 97 (E.D. Pa. 1986). “§ 1952 (the Travel Act), and 18 Pa.C.S. § 4108 (commercial bribery) with particularity in accordance with Fed.”

Westlake Plastic Co. v. O'Donnell, 182 F.R.D. 165 (E.D. Pa. 1998). “Accordingly, Westlake’s allegation that O’Donnell engaged in commercial bribery in violation of 18 Pa.C.S. § 4108 also constitutes a predicate act for purposes of its civil RICO claim.”

United States v. Harder, 168 F. Supp. 3d 732 (E.D. Pa. 2016). “”); 18 Pa. Cons. Stat. § 4108 ; 18 Pa. Cons. Stat.”

— 18 Pa. Cons. Stat. § 4108(b) — 2 cases

Brokerage Concepts v. US Healthcare Inc (Part II), 140 F.3d 494 (3rd Cir. 1998). “§ 1951 ; (2) violation of Pennsylvania’s commercial bribery statute, 18 Pa. Cons.Stat. § 4108(b); (3) mail fraud, 18 U.”

— 18 Pa. Cons. Stat. § 4108(c) — 2 cases

Temple Univ. v. Salla Bros., Inc., 656 F. Supp. 97 (E.D. Pa. 1986). “§ 1952 (the Travel Act), and 18 Pa.C.S. § 4108 (commercial bribery) with particularity in accordance with Fed.”

United States v. Louis Parise, Jr., 159 F.3d 790 (3rd Cir. 1998). “21, § 380; Pennsylvania, see 18 Pa. Cons.Stat. Ann. § 4108; Rhode Island, see R.”

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