Pennsylvania Consolidated Statutes

42 Pa. Cons. Stat. § 4548 (2026)

  Powers of investigating grand jury.

✓ 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.
Find cases: SyfertCases citing this section PA-LEGpalegis.us JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

§ 4548.  Powers of investigating grand jury.

(a)  General rule.--The investigating grand jury shall have the power to inquire into offenses against the criminal laws of the Commonwealth alleged to have been committed within the county or counties in which it is summoned. Such power shall include the investigative resources of the grand jury which shall include but not be limited to the power of subpoena, the power to obtain the initiation of civil and criminal contempt proceedings, and every investigative power of any grand jury of the Commonwealth. Such alleged offenses may be brought to the attention of such grand jury by the court or by the attorney for the Commonwealth, but in no case shall the investigating grand jury inquire into alleged offenses on its own motion.

(b)  Presentments.--The investigating grand jury shall have the power to issue a presentment with regard to any person who appears to have committed within the county or counties in which such investigating grand jury is summoned an offense against the criminal laws of the Commonwealth.

(c)  Other powers.--Except for the power to indict, the investigating grand jury shall have every power available to any other grand jury in the Commonwealth. The jurisdiction, powers and activities of an investigating grand jury shall not, if otherwise lawful, be limited in any way by the charge of the court.

Notes of Decisions
Cited in 16 cases (2 in the last 5 years), 1981–2025 · leading case: In Re: Return of Seized Prop. of Lackawanna Cty, 212 A.3d 1 (Pa. 2019).
In Re: Return of Seized Prop. of Lackawanna Cty, 212 A.3d 1 (Pa. 2019). · cites it 8× “We thus begin by considering whether Judge Sarcione, as Supervising Judge of the 41st Statewide 10 The Pennsylvania Association of Criminal Defense Lawyers (“PACDL”) has filed an amicus curiae brief in support of the County focusing “solely on the statutory construction of 42…”
In Re the Twenty-Fourth Statewide Investigating Grand Jury, 907 A.2d 505 (Pa. 2006). · cites it 6× “newspaper's argument confuses the statutory prerequisites for empanelment of a statewide investigating grand jury as outlined in Section 4544 of the Judicial Code, with the statutory powers of an existing county, multi-county, or statewide grand jury to inquire into offenses…”
In Re Investigating Grand Jury, Etc., 433 A.2d 5 (Pa. 1981). · cites it 10× “The sole support for petitioner's argument is his reading of 42 Pa.C.S. § 4548(a), formerly 19 P.S. § 271, (Act of November 22, 1978, P.”
Commonwealth v. Sandusky, 203 A.3d 1033 (Pa. Super. Ct. 2019). “42 Pa.C.S. § 4548(a). § 4550. Submission of investigations by attorney for the Commonwealth to investigating grand jury (a) General rule.”
In Re the Thirty-Fifth Statewide Investigating Grand Jury, 112 A.3d 624 (Pa. 2015). · cites it 3× “42 Pa.C.S. §§ 4548; 4551. Indeed, a review of the entire Investigatory Grand Jury Act reflects the distinct role of the executive, as prosecutor charged with guiding the grand jury process, and the role of the judiciary, as a neutral, responsible for supervising the proceedings.”
Commonwealth v. McCauley, 588 A.2d 941 (Pa. Super. Ct. 1991). · cites it 2× “Powers of investigating grand jury, 42 Pa.C.S. § 4548, provides: (a) General rule.”
Commonwealth, Aplt. v. Pownall, R. (Pa. 2022). · cites it 2× “” 42 Pa.C.S. §4548(a). If it “appears” to the grand jury a criminal offense has been committed, it may “issue a presentment[.”
In Re: Return of Seized Prop. of Lackawanna Cty (Pa. 2019). “42 Pa.C.S. § 4548(a), (c) (emphasis added).”
In Re: Grand Jury Investigation No. 18 (Pa. 2020). “§ 4544, and the crimes that can thereafter be investigated, 42 Pa.C.S. § 4548(a), this Court eradicated the distinction between county and multicounty investigating grand juries so clearly delineated in the Act.”
Com. v. Kiessling, C., 2025 Pa. Super. 162 (Pa. Super. Ct. 2025). “” See 42 Pa.C.S. § 4548. Should the grand jury determine upon the basis of evidence presented to it that a presentment is warranted, the presentment must be approved by a majority of the grand jury’s full membership, which is typically twenty-three voting members, before it is…”
In Re: 35th Statewide Inv Grand Jury / Pet of: AG (Pa. 2015). “§ 4549(b); the ability of a judge to bring alleged offenses to the attention of an investigating grand jury, 42 Pa.C.S. § 4548(a); and a supervising judge’s general powers required or incidental to the exercise of jurisdiction, 42 Pa.”
In Re: The Thirty-Five Statewide Investigating Grand Jury Pet of: Attorney Gen. Kathleen Kane (Pa. 2015). “The argument of Attorney General Kane that she is not subject to the subpoena because it is outside the purview of the Special Prosecutor is directl counte y red by application of 42 Pa. C.S. §4548(a), which in relevant part provides as follows: §4548(a) Powers of investigating…”
— 42 Pa. Cons. Stat. § 4548(a) — 13 cases
In Re the Twenty-Fourth Statewide Investigating Grand Jury, 907 A.2d 505 (Pa. 2006). “newspaper's argument confuses the statutory prerequisites for empanelment of a statewide investigating grand jury as outlined in Section 4544 of the Judicial Code, with the statutory powers of an existing county, multi-county, or statewide grand jury to inquire into offenses…”
In Re: Return of Seized Prop. of Lackawanna Cty, 212 A.3d 1 (Pa. 2019). “We thus begin by considering whether Judge Sarcione, as Supervising Judge of the 41st Statewide 10 The Pennsylvania Association of Criminal Defense Lawyers (“PACDL”) has filed an amicus curiae brief in support of the County focusing “solely on the statutory construction of 42…”
In Re Investigating Grand Jury, Etc., 433 A.2d 5 (Pa. 1981). “The sole support for petitioner's argument is his reading of 42 Pa.C.S. § 4548(a), formerly 19 P.S. § 271, (Act of November 22, 1978, P.”
Commonwealth v. Sandusky, 203 A.3d 1033 (Pa. Super. Ct. 2019). “42 Pa.C.S. § 4548(a). § 4550. Submission of investigations by attorney for the Commonwealth to investigating grand jury (a) General rule.”
In Re the Thirty-Fifth Statewide Investigating Grand Jury, 112 A.3d 624 (Pa. 2015). “42 Pa.C.S. §§ 4548; 4551. Indeed, a review of the entire Investigatory Grand Jury Act reflects the distinct role of the executive, as prosecutor charged with guiding the grand jury process, and the role of the judiciary, as a neutral, responsible for supervising the proceedings.”
— 42 Pa. Cons. Stat. § 4548(c) — 1 case
Commonwealth, Aplt. v. Pownall, R. (Pa. 2022). “” 42 Pa.C.S. §4548(a). If it “appears” to the grand jury a criminal offense has been committed, it may “issue a presentment[.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.