Pretrial detention; Bail Reform Act; 18 USC § 3142(e)(1); Statutory rebuttable presumption; § 3142(e)(3)(D); Forced labor; § 1589(d); Conspiracy to commit forced labor; § 1594(b); Review of detention order; § 3145(b); Appeal from detention order; § 3145(c); Motion for reconsideration; ED MI LR 7.1(h)(1) & (2); Miller v William Beaumont Hospital; Blackwell v Nocerini; Dangerousness factors; § 3142(g); Clear & convincing evidence; United States v Stone; First Amendment; Religious conduct; United States v Greene; Conditions of release

[This appeal was from the ED-MI.] The court held that defendant’s appeal from the pretrial detention order was timely but that no condition or combination of conditions would reasonably assure community safety if he were released. Defendant, the leader of Kingdom of God Global Church, was indicted on forced-labor, forced-labor-conspiracy, and money-laundering-conspiracy charges. A magistrate judge ordered him detained, and the district court denied his motion to revoke detention and later denied reconsideration. On appeal, the court first rejected the government’s timeliness argument. It reasoned that under Nocerini, ED-MI LR 7.1(h)(1) “cover[s] only an order completing the case,” while detention orders are final and appealable but do not terminate the criminal case. Thus, the reconsideration motion tolled the appeal period. The court next held that the § 3142(g) factors supported detention. Although defendant produced “some” evidence rebutting the statutory presumption, that presumption remained relevant, and the indictment alleged coercion through spiritual threats, physical violence, sleep and food deprivation, sexual exploitation, and threats against workers. The court rejected defendant’s First Amendment challenge because the detention ruling was based on “charged criminal conduct,” not religious belief, and “‘religious conduct remains subject to regulation for the protection of society.’” It also held that the district court did not err by crediting the government’s violence proffer, and release conditions would not adequately address the danger because the record showed defendant routinely used others to “coerce, threaten, and punish his victims.” Affirmed.