Pennsylvania Consolidated Statutes

42 Pa. Cons. Stat. § 4549 (2026)

  Investigating grand jury proceedings.

✓ current as of May 2026
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§ 4549.  Investigating grand jury proceedings.

(a)  Documents and transcript.--Any document produced before an investigating grand jury may be copied or reproduced. Each statement, question, comment or response of the supervising judge, the attorney for the Commonwealth, any witness, any grand juror or any other person which is made in the presence of the investigating grand jury, except its deliberations and the vote of any juror, shall be stenographically recorded or transcribed or both.

(b)  Disclosure of proceedings by participants other than witnesses.--Disclosure of matters occurring before the grand jury other than its deliberations and the vote of any juror may be made to the attorneys for the Commonwealth for use in the performance of their duties. The attorneys for the Commonwealth may with the approval of the supervising judge disclose matters occurring before the investigating grand jury including transcripts of testimony to local, State, other state or Federal law enforcement or investigating agencies to assist them in investigating crimes under their investigative jurisdiction. Otherwise a juror, attorney, interpreter, stenographer, operator of a recording device, or any typist who transcribes recorded testimony may disclose matters occurring before the grand jury only when so directed by the court. All such persons shall be sworn to secrecy, and shall be in contempt of court if they reveal any information which they are sworn to keep secret.

(c)  Counsel for witnesses.--

(1)  A witness subpoenaed to appear and testify before an investigating grand jury or to produce documents, records or other evidence before an investigating grand jury shall be entitled to the assistance of counsel, including assistance during such time as the witness is questioned in the presence of the investigating grand jury. In the event counsel of the witness' choice is not available, he shall be required to obtain other counsel within a reasonable time in order that the work of the grand jury may proceed.

(2)  Such counsel may be retained by the witness or shall be appointed in the case of any person unable to procure sufficient funds to obtain legal representation.

(3)  Such counsel shall be allowed to be present in the grand jury room during the questioning of the witness and shall be allowed to advise the witness but shall make no objections or arguments or otherwise address the grand jury or the attorney for the Commonwealth. The supervising judge shall have the same power to remove such counsel from the grand jury room as a judge has with respect to an attorney in any court proceeding. Violation of this paragraph shall be punishable as contempt by the supervising judge.

(4)  An attorney, or attorneys who are associated in practice, shall not continue multiple representation of clients in a grand jury proceeding if the exercise of the independent professional judgment of an attorney on behalf of one of the clients will or is likely to be adversely affected by his representation of another client. If the supervising judge determines that the interest of an individual will or is likely to be adversely affected, he may order separate representation of witnesses, giving appropriate weight to the right of an individual to counsel of his own choosing.

(d)  Disclosure of proceedings by witnesses.--No witness shall be prohibited from disclosing his testimony before the investigating grand jury except for cause shown in a hearing before the supervising judge. In no event may a witness be prevented from disclosing his testimony to his attorney.

Notes of Decisions
Cited in 47 cases (7 in the last 5 years), 1981–2025 · leading case: In Re Fortieth Statewide Investigating Grand Jury, 191 A.3d 750 (Pa. 2018).
In Re Fortieth Statewide Investigating Grand Jury, 191 A.3d 750 (Pa. 2018). · cites it 32× “See 42 Pa.C.S. §4549(b). In the first instance, the enactment’s Section 4549(b) authorizes disclosure of such matters generally to “attorneys for the Commonwealth” for use in the performance of their duties.”
Com. v. Boyer, A., 282 A.3d 1161 (Pa. Super. Ct. 2022). · cites it 6× “42 Pa.C.S. § 4549(d) Cause Hearing – Whether the trial court lacked jurisdiction to enter a September 5, 2019 witness nondisclosure order where Appellant moved for the release of the unredacted transcript and there was no evidence that a cause hearing prior to the nondisclosure…”
In Re Investigating Grand Jury, 437 A.2d 1128 (Pa. 1981). · cites it 10× “— Disclosure of matters occurring before the grand jury other than its deliberations and the vote of any juror may be made to the attorneys for the Commonwealth for use in the performance of their duties.”
Levy v. Senate of Pennsylvania, 94 A.3d 436 (Pa. Commw. Ct. 2014). · cites it 6× “Specifically, Section 4549(b) provides, with emphasis added: Disclosure of matters occurring before the grand jury other than its deliberations and the vote of any juror may be made to the attorneys for the Commonwealth for use in the performance of their duties.”
In Re the Thirty-Fifth Statewide Investigating Grand Jury, 112 A.3d 624 (Pa. 2015). · cites it 12× “See generally 42 Pa.C.S. §4549(b) (providing that jurors, attorneys, interpreters, stenographers, recording-device operators, or typists shall be sworn to secrecy and may disclose matters occurring before an investigating grand jury only when so directed by the court, on pain of…”
Castellani v. Scranton Times, L.P., 956 A.2d 937 (Pa. 2008). · cites it 4× “42 Pa.C.S. § 4549(b). The reasons for ensuring grand jury secrecy have been described as follows: (1) To prevent the escape of those whose indictment may be contemplated; (2) to insure the utmost freedom to the grand jury in its deliberations, and to *952 prevent persons subject…”
Commonwealth v. Schultz, 133 A.3d 294 (Pa. Super. Ct. 2016). · cites it 3× “42 Pa.C.S. § 4549(c) (emphases added). Thus, the Grand Jury Act provides a right to counsel during the grand jury proceeding itself.”
In Re Dauphin Cnty. Fourth Investigating Grand Jury, 19 A.3d 491 (Pa. 2011). · cites it 3× “42 Pa.C.S. § 4549(b). Furthermore, although grand jury witnesses are generally permitted to disclose their testimony to others, the supervising judge may prohibit such disclosure “for cause shown.”
Castellani, R., Aplts. v. Scranton Times, 124 A.3d 1229 (Pa. 2015). · cites it 2× “Following the investigation, Judge Garb reviewed the special prosecutor’s report and the grand jury transcripts (neither of which 1 See 42 Pa.C.S. § 4549 (providing for disclosure of grand jury information only in limited circumstances; “[o]therwise a juror, attorney,…”
In Re the Twenty-Fourth Statewide Investigating Grand Jury, 907 A.2d 505 (Pa. 2006). · cites it 2× “" 42 Pa.C.S. § 4549(b). Further, the Attorney General contends that compelled disclosure would jeopardize the reputation of high public *515 officials who find themselves under grand jury investigation.”
In re Fortieth Statewide Investigating Grand Jury, 190 A.3d 560 (Pa. 2018). “See 42 Pa.C.S. § 4549(b). Prior to the expiration of its term, the 40th Statewide Investigating Grand Jury submitted a report of the above investigation to its supervising judge, the Honorable Norman A.”
In Re: Return of Seized Prop. of Lackawanna Cty, 212 A.3d 1 (Pa. 2019). · cites it 2× “229 and 42 Pa.C.S. §4549. Id. at 3. After the 41st Statewide Investigating Grand Jury was empaneled and an investigation was ongoing, an OAG Special Agent and a Pennsylvania State Trooper applied to Judge Sarcione for four warrants to search and seize certain property belonging…”
— 42 Pa. Cons. Stat. § 4549(1981) — 1 case
In re Fifth Statewide Investigating Grand Jury, 44 Pa. D. & C.3d 339 (1987).
— 42 Pa. Cons. Stat. § 4549(a) — 1 case
In re Fifth Statewide Investigating Grand Jury, 44 Pa. D. & C.3d 339 (1987).
— 42 Pa. Cons. Stat. § 4549(b) — 21 cases
In Re Fortieth Statewide Investigating Grand Jury, 191 A.3d 750 (Pa. 2018). “See 42 Pa.C.S. §4549(b). In the first instance, the enactment’s Section 4549(b) authorizes disclosure of such matters generally to “attorneys for the Commonwealth” for use in the performance of their duties.”
In Re Investigating Grand Jury, 437 A.2d 1128 (Pa. 1981). “— Disclosure of matters occurring before the grand jury other than its deliberations and the vote of any juror may be made to the attorneys for the Commonwealth for use in the performance of their duties.”
In Re the Thirty-Fifth Statewide Investigating Grand Jury, 112 A.3d 624 (Pa. 2015). “See generally 42 Pa.C.S. §4549(b) (providing that jurors, attorneys, interpreters, stenographers, recording-device operators, or typists shall be sworn to secrecy and may disclose matters occurring before an investigating grand jury only when so directed by the court, on pain of…”
Castellani v. Scranton Times, L.P., 956 A.2d 937 (Pa. 2008). “42 Pa.C.S. § 4549(b). The reasons for ensuring grand jury secrecy have been described as follows: (1) To prevent the escape of those whose indictment may be contemplated; (2) to insure the utmost freedom to the grand jury in its deliberations, and to *952 prevent persons subject…”
Levy v. Senate of Pennsylvania, 94 A.3d 436 (Pa. Commw. Ct. 2014). “Specifically, Section 4549(b) provides, with emphasis added: Disclosure of matters occurring before the grand jury other than its deliberations and the vote of any juror may be made to the attorneys for the Commonwealth for use in the performance of their duties.”
— 42 Pa. Cons. Stat. § 4549(c) — 5 cases
Commonwealth v. Schultz, 133 A.3d 294 (Pa. Super. Ct. 2016). “42 Pa.C.S. § 4549(c) (emphases added). Thus, the Grand Jury Act provides a right to counsel during the grand jury proceeding itself.”
In Re Fortieth Statewide Investigating Grand Jury, 191 A.3d 750 (Pa. 2018). “See 42 Pa.C.S. §4549(b). In the first instance, the enactment’s Section 4549(b) authorizes disclosure of such matters generally to “attorneys for the Commonwealth” for use in the performance of their duties.”
Commonwealth v. Wright, 865 A.2d 894 (Pa. Super. Ct. 2004).
— 42 Pa. Cons. Stat. § 4549(c)(1) — 6 cases
In Re Fortieth Statewide Investigating Grand Jury, 191 A.3d 750 (Pa. 2018). “See 42 Pa.C.S. §4549(b). In the first instance, the enactment’s Section 4549(b) authorizes disclosure of such matters generally to “attorneys for the Commonwealth” for use in the performance of their duties.”
In re Bucks Cnty. Investigating Grand Jury, 861 A.2d 876 (Pa. 2004).
— 42 Pa. Cons. Stat. § 4549(c)(2) — 1 case
— 42 Pa. Cons. Stat. § 4549(c)(4) — 3 cases
Commonwealth v. Schultz, 133 A.3d 294 (Pa. Super. Ct. 2016). “42 Pa.C.S. § 4549(c) (emphases added). Thus, the Grand Jury Act provides a right to counsel during the grand jury proceeding itself.”
In re Bucks Cnty. Investigating Grand Jury, 861 A.2d 876 (Pa. 2004).
— 42 Pa. Cons. Stat. § 4549(c)(l) — 1 case
— 42 Pa. Cons. Stat. § 4549(d) — 9 cases
Com. v. Boyer, A., 282 A.3d 1161 (Pa. Super. Ct. 2022). “42 Pa.C.S. § 4549(d) Cause Hearing – Whether the trial court lacked jurisdiction to enter a September 5, 2019 witness nondisclosure order where Appellant moved for the release of the unredacted transcript and there was no evidence that a cause hearing prior to the nondisclosure…”
In Re Fortieth Statewide Investigating Grand Jury, 191 A.3d 750 (Pa. 2018). “See 42 Pa.C.S. §4549(b). In the first instance, the enactment’s Section 4549(b) authorizes disclosure of such matters generally to “attorneys for the Commonwealth” for use in the performance of their duties.”
Levy v. Senate of Pennsylvania, 94 A.3d 436 (Pa. Commw. Ct. 2014). “Specifically, Section 4549(b) provides, with emphasis added: Disclosure of matters occurring before the grand jury other than its deliberations and the vote of any juror may be made to the attorneys for the Commonwealth for use in the performance of their duties.”
In Re Dauphin Cnty. Fourth Investigating Grand Jury, 19 A.3d 491 (Pa. 2011). “42 Pa.C.S. § 4549(b). Furthermore, although grand jury witnesses are generally permitted to disclose their testimony to others, the supervising judge may prohibit such disclosure “for cause shown.”
First Amendment Coalition v. Jud. Inquiry & Review Bd., 579 F. Supp. 192 (E.D. Pa. 1984).
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