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Criminal Procedure-Restitution

7th Circuit Court of Appeals

Case Name: United States of America v. Tracie Dickey

Case No.: 21-2522

Officials: Wood, St. Eve, and Jackson‐Akiwumi, Circuit Judges.

Focus: Criminal Procedure-Restitution

Tracie Dickey, the leader of her own church, Deliverance Tabernacle Ministries International, claimed to be a prophet who received commands from God. Her worshipers (in reality, victims) had to live in church space and work several jobs. All money earned went to Dickey, who used the funds to pay for personal expenses. She used physical and mental coercion to ensure compliance with her demands.

Having been convicted of one count of wire fraud, 18 U.S.C. § 1343, and one count of forced labor, 18 U.S.C. § 1589, for her actions, Dickey challenges three of the district court’s rulings: the denial of her fourth motion to continue her trial, the 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.


Decided 10/28/22

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