The House Select Committee has voted to refer Steve Bannon to the Department of Justice for a criminal contempt prosecution. If the full House votes the same way, then Bannon will become the "target" of a grand jury investigation.
Every grand jury proceeding involves not just an investigation of the crime and the suspected criminal, but an investigation of the motive. Given that Bannon's motive in refusing to comply with a congressional subpoena to testify about the January 6 attack on the US Capitol almost certainly includes a desire to avoid incriminating Donald Trump, the matter of Trump's previous pardon of Bannon is a matter ripe for the grand jury's consideration. This will result in Donald Trump being deemed a "subject" of the grand jury's investigation.
This video explores the DOJ guidelines, found in the US Attoneys' Manual, defining terms like "target" and "subject" as those terms relate to a grand jury investigation, and why Trump is likely soon to find himself a "subject."
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