Pennsylvania Consolidated Statutes

42 Pa. Cons. Stat. § 4552 (2026)

  Investigating grand jury reports.

✓ current as of May 2026
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§ 4552.  Investigating grand jury reports.

(a)  General rule.--Any investigating grand jury, by an affirmative majority vote of the full investigating grand jury, may, at any time during its term submit to the supervising judge an investigating grand jury report.

(b)  Examination by court.--The judge to whom such report is submitted shall examine it and the record of the investigating grand jury and, except as otherwise provided in this section, shall issue an order accepting and filing such report as a public record with the court of common pleas established for or embracing the county or counties which are the subject of such report only if the report is based upon facts received in the course of an investigation authorized by this subchapter and is supported by the preponderance of the evidence.

(c)  Sealed report.--Upon the submission of a report pursuant to subsection (a), if the supervising judge finds that the filing of such report as a public record may prejudice fair consideration of a pending criminal matter, he shall order such report sealed and such report shall not be subject to subpoena or public inspection during the pendency of such criminal matter except upon order of court.

(d)  Appeal from refusal to file.--Failure of the supervising judge to accept and file as a public record a report submitted under this section may be appealed by the attorney for the Commonwealth to the Supreme Court in the manner prescribed by general rules.

(e)  Authorization of response by nonindicted subject.--If the supervising judge finds that the report is critical of an individual not indicted for a criminal offense the supervising judge may in his sole discretion allow the named individual to submit a response to the allegations contained in the report. The supervising judge may then in his discretion allow the response to be attached to the report as part of the report before the report is made part of the public record pursuant to subsection (b).

Notes of Decisions
Cited in 8 cases (3 in the last 5 years), 1981–2026 · leading case: In re Fortieth Statewide Investigating Grand Jury, 190 A.3d 560 (Pa. 2018).
In re Fortieth Statewide Investigating Grand Jury, 190 A.3d 560 (Pa. 2018). · cites it 8× “See 42 Pa.C.S. § 4552. Significantly, the report is not generally couched in conventional "investigatory" terms, such as by allusion to the character and quality of the evidence reviewed according to the application of a probable cause standard.”
In re Fortieth Statewide Investigating Grand Jury, 197 A.3d 712 (Pa. 2018). · cites it 9× “See 42 Pa.C.S. § 4552(a). If the submitted report still includes references critical of a named but nonindicted individual, it should be supported by citation to all specific exhibits or transcript pages pertinent to that individual.”
In Re Investigating Grand Jury, Etc., 433 A.2d 5 (Pa. 1981). · cites it 2× “§ 4552, the grand jury states: "On September 9, 1980, we issued a presentment charging four employees, David Bohannon, Richard Drapczuk, John Majewski and Richard Wolf with participation in the conspiracy to defraud the City. Our investigation continued after charges were filed…”
In Re: The 30th Cnty. Investigating Grand Jury (Pa. 2024). · cites it 6× “” 42 Pa.C.S. § 4552(a). A supervising judge who receives an investigatory grand jury report must examine the report and the record of the grand jury and, except in certain limited circumstances, issue an order accepting and filing such report as a public record with the court of…”
In Re: The 30th Cnty. Investigating Grand Jury (Pa. 2024). · cites it 2× “42 Pa.C.S. §§ 4552 (a)-(b) (emphasis added).”
In Re: Grand Jury Investigation No. 18 (Pa. 2020). “42 Pa.C.S. § 4552(a). If a supervising judge receives an investigating grand jury report, she must, in pertinent part, examine the report and the record of the investigating grand jury, and issue an order accepting and filing such report as a public record with the court of…”
In re: Crim. Investn. No. CID 18-2673 Balt. City Circuit Court (Md. 2026). “42 Pa. Cons. Stat. § 4552 (a). If the supervising judge finds that the report is critical of an uncharged person, the judge may permit that person to submit a response to the allegations in the report.”
Commonwealth v. Corban Corp., 77 Pa. D. & C.4th 90 (2005). “§5552 as applicable to offenses defined by the Crimes Code. 18 Pa.C.S. §107 provides that the provisions of Part I of the Crimes Code apply to offenses defined by any statute.”
— 42 Pa. Cons. Stat. § 4552(a) — 3 cases
In re Fortieth Statewide Investigating Grand Jury, 197 A.3d 712 (Pa. 2018). “See 42 Pa.C.S. § 4552(a). If the submitted report still includes references critical of a named but nonindicted individual, it should be supported by citation to all specific exhibits or transcript pages pertinent to that individual.”
In Re: The 30th Cnty. Investigating Grand Jury (Pa. 2024). “” 42 Pa.C.S. § 4552(a). A supervising judge who receives an investigatory grand jury report must examine the report and the record of the grand jury and, except in certain limited circumstances, issue an order accepting and filing such report as a public record with the court of…”
In Re: Grand Jury Investigation No. 18 (Pa. 2020). “42 Pa.C.S. § 4552(a). If a supervising judge receives an investigating grand jury report, she must, in pertinent part, examine the report and the record of the investigating grand jury, and issue an order accepting and filing such report as a public record with the court of…”
— 42 Pa. Cons. Stat. § 4552(b) — 4 cases
In re Fortieth Statewide Investigating Grand Jury, 197 A.3d 712 (Pa. 2018). “See 42 Pa.C.S. § 4552(a). If the submitted report still includes references critical of a named but nonindicted individual, it should be supported by citation to all specific exhibits or transcript pages pertinent to that individual.”
In re Fortieth Statewide Investigating Grand Jury, 190 A.3d 560 (Pa. 2018). “See 42 Pa.C.S. § 4552. Significantly, the report is not generally couched in conventional "investigatory" terms, such as by allusion to the character and quality of the evidence reviewed according to the application of a probable cause standard.”
In Re: The 30th Cnty. Investigating Grand Jury (Pa. 2024). “” 42 Pa.C.S. § 4552(a). A supervising judge who receives an investigatory grand jury report must examine the report and the record of the grand jury and, except in certain limited circumstances, issue an order accepting and filing such report as a public record with the court of…”
In Re: The 30th Cnty. Investigating Grand Jury (Pa. 2024). “42 Pa.C.S. §§ 4552 (a)-(b) (emphasis added).”
— 42 Pa. Cons. Stat. § 4552(e) — 3 cases
In re Fortieth Statewide Investigating Grand Jury, 190 A.3d 560 (Pa. 2018). “See 42 Pa.C.S. § 4552. Significantly, the report is not generally couched in conventional "investigatory" terms, such as by allusion to the character and quality of the evidence reviewed according to the application of a probable cause standard.”
In re Fortieth Statewide Investigating Grand Jury, 197 A.3d 712 (Pa. 2018). “See 42 Pa.C.S. § 4552(a). If the submitted report still includes references critical of a named but nonindicted individual, it should be supported by citation to all specific exhibits or transcript pages pertinent to that individual.”
In Re: The 30th Cnty. Investigating Grand Jury (Pa. 2024). “” 42 Pa.C.S. § 4552(a). A supervising judge who receives an investigatory grand jury report must examine the report and the record of the grand jury and, except in certain limited circumstances, issue an order accepting and filing such report as a public record with the court of…”
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