[dragonwriter]

The difference seems to be that a US grand jury can indict on a prosecutors motion (and even, IIRC, in certain cases independently), but no one is obligated to prosecute based on an indictment once it is issued (obviously, one sought by a prosecutor will probably usually be followed up on by that prosecutor.)

But, from the description in the article, when a citizens' panel finds that charges should be issued after a prosecutor has decided not to prosecute, the case is reopened by prosecutors. Assuming this isn't just a reconsideration where the prosecutor can again decide not to actually prosecute the charges, this is a fairly substantial difference.