Pa. Cons. Stat. » 61 Pa. Cons. Stat. (PRISONS AND PAROLE) / Chapter 61
Pennsylvania Consolidated Statutes

61 Pa. Cons. Stat. § 6182 (2026)

 Supervisory relationship to offenders.

✓ current as of May 2026
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§ 6182.  Supervisory relationship to offenders.

(a)  General rule.--Agents are in a supervisory relationship with department-supervised offenders. The purpose of supervision is to assist department-supervised offenders in their rehabilitation and reassimilation into the community and to protect the public. Supervision practices shall reflect the balance of enforcement of the conditions of supervision and case management techniques to maximize successful parole completion through effective reentry to society.

(b)  Searches and seizures authorized.--

(1)  Agents may search the person and property of department-supervised offenders in accordance with the provisions of this section.

(2)  Nothing in this section shall be construed to permit searches or seizures in violation of the Constitution of the United States or section 8 of Article I of the Constitution of Pennsylvania.

(c)  Effect of violation.--No violation of this section shall constitute an independent ground for suppression of evidence in any probation, parole or criminal proceeding.

(d)  Grounds for personal search of a department-supervised offender.--

(1)  A personal search of an offender may be conducted by an agent:

(i)  if there is a reasonable suspicion to believe that the department-supervised offender possesses contraband or other evidence of violations of the conditions of supervision;

(ii)  when a department-supervised offender is transported or taken into custody; or

(iii)  upon a department-supervised offender entering or leaving the secure enclosure of a correctional institution, jail or detention facility.

(2)  A property search may be conducted by an agent if there is reasonable suspicion to believe that the real or other property in the possession of or under the control of the department-supervised offender contains contraband or other evidence of violations of the conditions of supervision.

(3)  The department-supervised offender may be detained if the department-supervised offender is present during a property search. If the department-supervised offender is not present during a property search, the agent in charge of the search shall make a reasonable effort to provide the department-supervised offender with notice of the search, including a list of the items seized, after the search is completed.

(4)  The existence of reasonable suspicion to search shall be determined in accordance with constitutional search and seizure provisions as applied by judicial decision. In accordance with such case law, the following factors, where applicable, may be taken into account:

(i)  The observations of agents.

(ii)  Information provided by others.

(iii)  The activities of the department-supervised offender.

(iv)  Information provided by the department-supervised offender.

(v)  The experience of agents with the department-supervised offender.

(vi)  The experience of agents in similar circumstances.

(vii)  The prior criminal and supervisory history of the department-supervised offender.

(viii)  The need to verify compliance with the conditions of supervision.

(e)  Nonresident department-supervised offenders.--No agent shall conduct a personal or property search of a department-supervised offender who is residing in a foreign state except for the limited purposes permitted under the Interstate Compact for the Supervision of Offenders and Probationers. The department-supervised offender is held accountable to the rules of both the sending state and the receiving state. Any personal or property search of a department-supervised offender residing in another state shall be conducted by an agent of the receiving state.

(f)  When authority is effective.--The authority granted to agents under this section shall be effective upon enactment of this section, without the necessity of any further regulation by the department.

Notes of Decisions
Cited in 6 cases (6 in the last 5 years), 2022–2025 · leading case: Com. v. Folkes, L. (Pa. Super. Ct. 2025).
Sort: Relevance Newest Treatment
Com. v. Folkes, L. (Pa. Super. Ct. 2025). · cites it 8× “, which included Appellant’s prior criminal history involving firearms, the agents’ direct observations, the location and timing of the interaction, Appellant’s evasive behavior in asking a third party to open the glove box and distancing himself from that area of the car, and…”
Com. v. Mummaw, C. (Pa. Super. Ct. 2025). · cites it 2× “” 61 Pa.C.S. § 6182(d)(2). Despite this authority, agents “may not act as ‘stalking horses’ for the police,” who are subject to higher suspicion standards before performing searches.”
James v. Bachman (E.D. Pa. 2022). “61 Pa. Cons. Stat. Ann. § 6182(d)(3). James fails to plausibly allege that the parole officials lacked a reasonable suspicion to conduct the search.”
James v. Bachman (E.D. Pa. 2022). “2 James, 2022 WL 1469749 , at *3. James attempts to meet this burden in several ways.”
Com. v. Gibson, T., 2025 Pa. Super. 65 (Pa. Super. Ct. 2025). “It would be “anomalous to hold that parole officers may carry weapons like peace officers, place themselves in peril like peace officers, and ____________________________________________ 6 That statute was repealed in 2021 and is now codified at 61 Pa.C.S. § 6182. 7 This statute…”
Com. v. Stoney, T., 2025 Pa. Super. 232 (Pa. Super. Ct. 2025). “It ____________________________________________ 3 That statute was repealed in 2021 and is now codified at 61 Pa.C.S. § 6182. 4 This statute is now codified at 61 Pa.”
— 61 Pa. Cons. Stat. § 6182(d) — 1 case
Com. v. Folkes, L. (Pa. Super. Ct. 2025). “, which included Appellant’s prior criminal history involving firearms, the agents’ direct observations, the location and timing of the interaction, Appellant’s evasive behavior in asking a third party to open the glove box and distancing himself from that area of the car, and…”
— 61 Pa. Cons. Stat. § 6182(d)(2) — 2 cases
Com. v. Folkes, L. (Pa. Super. Ct. 2025). “, which included Appellant’s prior criminal history involving firearms, the agents’ direct observations, the location and timing of the interaction, Appellant’s evasive behavior in asking a third party to open the glove box and distancing himself from that area of the car, and…”
Com. v. Mummaw, C. (Pa. Super. Ct. 2025). “” 61 Pa.C.S. § 6182(d)(2). Despite this authority, agents “may not act as ‘stalking horses’ for the police,” who are subject to higher suspicion standards before performing searches.”
— 61 Pa. Cons. Stat. § 6182(d)(3) — 1 case
James v. Bachman (E.D. Pa. 2022). “61 Pa. Cons. Stat. Ann. § 6182(d)(3). James fails to plausibly allege that the parole officials lacked a reasonable suspicion to conduct the search.”
— 61 Pa. Cons. Stat. § 6182(d)(4) — 1 case
Com. v. Folkes, L. (Pa. Super. Ct. 2025). “, which included Appellant’s prior criminal history involving firearms, the agents’ direct observations, the location and timing of the interaction, Appellant’s evasive behavior in asking a third party to open the glove box and distancing himself from that area of the car, and…”
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