In United States v. Taylor, (ED MI, Nov. 9, 2026), a Michigan federal district court rejected free exercise and RFRA defenses to indictments charging multiple counts of forced labor and a count of conspiracy to commit money laundering. Defendant Taylor was the leader of the Kingdom of God Global Church. He created call centers to raise money for the Church and recruited individuals to work at them without pay. He set unreasonable goals for the solicitors, used them for other services and coerced them into furnishing sexually explicit photos and videos. He isolated them from family and friends and housed them at church facilities. The court said in part:
If workers attempted to leave KOGGC, Taylor told them they would suffer “consequences including sickness, accidents, death, and eternal damnation.”... When workers “disobeyed an order or failed to follow a rule,” Defendants imposed punishments, including “physical assault, additional work, sleep deprivation, food restrictions, loss of shelter, psychological abuse, and threats of spiritual damnation.”... Defendants also oversaw lengthy meetings where workers who had displeased them were humiliated and rebuked in front of other workers....
Taylor argues that his free-exercise rights extend beyond beliefs and shield his religious conduct from prosecution.... He also argues that the Government’s prosecution of him is premised on the view that he is a “false prophet.” This, he argues, improperly turns theological disapproval into a crime, because a jury must conclude that his beliefs are false to find him guilty.....
Even if these actions were religiously motivated, they are all actions. In turn, this allegedly criminal conduct is subject to regulation for the protection of society, even if Taylor committed it under the guise of religion. ....
The more difficult question is whether Taylor’s use of religious threats is actionable conduct. For example, the Indictment alleges that if KOGGC workers “disobeyed an order or failed to follow a rule,” Defendants would “claim the laborer was defying God and would suffer in hell.”... These allegations arguably straddle the border between conduct—speaking threats—and simply stating beliefs allegedly shared by Taylor and KOGGC members. This Court finds that these threats are actionable conduct, rather than unprosecutable religious beliefs....
RFRA provides broader protections than the First Amendment....
This Court finds that the prosecution is a substantial burden, meaning Taylor has established a prima facie case....
In this case, there is no way for the Government to enforce its interest in protecting KOGGC’s victims without enforcing § 1589 via criminal prosecution.... The Government has shown that there are no adequate, less restrictive options.
