United States v. Dickey, No. 21-2522 (7th Cir. 2022)
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As early as 2009, Dickey recruited followers for her church, “DTM,” grooming vulnerable victims and forcing them to disavow their families, live in the church, and work multiple full-time jobs. The victims gave Dickey all their wages, which she kept for herself. She required multiple victims to find employment at Hyatt hotels, where Dickey forced them to falsify reservation bookings, thereby fraudulently misdirecting kickbacks to Dickey’s own travel company. If someone disobeyed, Dickey threatened them with violence and required them to be homeless until she considered them redeemed. Her scheme netted $1.5 million, most of which came from DTM members. She spent over $1 million on personal expenses, such as travel, rental and vacation properties, and luxury hotels.
The Seventh Circuit affirmed Dickey’s convictions for wire fraud, 18 U.S.C. 1343, and forced labor, 18 U.S.C. 1589, upholding the district court’s denial of her fourth motion to continue her trial, rejection of a proposed jury instruction regarding religious liberty, and the imposition of restitution ordering her to pay for future mental health treatment for her victims. Dickey’s proposed instruction would have excused her criminal conduct based on her religious assertions and was not an accurate statement of the law.
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