With the woman set to be sentenced soon, one expert said her expected prison sentence points to a disparity in consequences for financial crimes committed within the Church.
Heather Darrey, former finance manager at Christ the King Parish in Tampa, Florida, pleaded guilty to wire fraud in June, after she was arrested on charges of stealing $775,000 from a parish operating account between October 2023 and March 2024.
But in August, prosecutors amended court documents, explaining that Darrey had actually stolen more.
“During a further review and audit” federal prosecutors told the court, “the parties discovered three additional checks made out to the defendant’s personal bank and credit accounts, that were in furtherance of the fraud scheme, totaling an additional $100,126.29.”
“The defendant agrees that these funds represent funds she obtained from the wire fraud scheme beyond those outlined in her plea agreement.”
While Darrey had originally pleaded guilty to stealing $775,000 from the parish where she worked, the amount taken actually exceeded $875,000.
Robert Warren, a retired IRS investigator and professor of accounting at Radford University, told The Pillar that the newly discovered funds are not likely to impact Darrey’s eventual sentencing.
“Sentence length in the federal system is based on a points system which includes numerous factors,” Warren explained.
“You start with a base number of points based on the offense itself. Additional points are added if the defendant abused a position of authority or trust, had a prior criminal history, or committed fraud against a vulnerable victim. Points are reduced if you take responsibility for your actions, and if you plead guilty to save the court and the government the expense of a trial.”
“Judges are also allowed to consider the general deterrent effect of the sentence, the health and age of the defendant, and his or her reputation in the community. So, an elderly Medal of Honor winner who steals $100,000 would probably get less jail time than a young and healthy repeat offender.”
Warren said that in his estimation, Darrey “is almost certain to get jail time based on her abusing a position of trust at the parish, and the fact that she stole from a non-profit organization.”
“If I were Ms. Darrey, I would come up with an exotic illness and bring all the sick relatives I could to the sentencing, and make the courthouse look like a scene out a Charles Dickens novel,” he told The Pillar
Barring that possibility, and considering similar cases, Warren said that he expects Darrey will likely be incarcerated for “two or three years, unless there are some unusual circumstances the judge takes into account.”
But Warren said that Darrey’s case exemplifies a disparity among sentences in Church theft or embezzlement cases — namely that priests convicted of financial crimes often serve less jail time than their lay counterparts, and sometimes none at all.
Warren’s scholarly research on the subject, conducted in partnership with scholar Timothy J. Fogarty, has concluded that a relatively small number of priests have been caught stealing from parishes, and that the priesthood does not seem to attract fraudsters or financial con artists.
When priests steal, the research found, they are often motivated by resentment, envy, and a desire to cover up for other moral lapses. The isolation of clerics, and weak oversight can contribute to the rationalization of theft through "moral licensing," Warren and Fogarty found.
But while clerical theft is relatively rare, when it does happen, priests and religious appear to have some advantages in the courtroom.
In his observation, “Catholic priests and sisters sentenced under federal sentencing guidelines appear to enjoy a ‘clergy privilege’ which results in lighter sentences than lay people who are sentenced for similar crimes,” Warren explained.
“While this has yet to be statistically proven, several anecdotal examples stand out,” Warren said, speaking from his experience as a researcher on theft in Catholic churches.
“For example, the layman who stole approximately $170,000 from the parish serving the University of North Carolina-Chapel Hill was sentenced to 57 months in prison. A Catholic priest from Connecticut who stole $300,000 from his parish and used some of the proceeds to fund a one-bedroom New York City apartment which he shared with a close male friend received a 5-month sentence.”
“A lay parish administrator from Wisconsin was sentenced to 33 months for stealing approximately $822,000 from her parish to fund a gambling habit. However, a Catholic priest in Maryland who stole $400,000 was sentenced to one day in jail, with time served.”
Warren acknowledged that the most well-known factor in reduced clergy sentences is the intervention of diocesan bishops in the sentencing process.
“Bishops often petition the court to impose a light sentence, so that the bishop may put the offending clergy member back to work in a job that does not provide access to money,” he said.
But episcopal intervention is not the only factor which might contribute to a sentencing disparity between clerics and laity.
One is that judges regard clerics as unlikely to commit more crimes, a factor in assigning sentencing points.
Another, Warren said, is that courts “may take into account the good works done by defendants when passing sentences.”
“A priest who is even just mediocre at his job can come up with scores of members of his parish, and past parishes, to attest to all of his good deeds, such as feeding the poor, visiting the imprisoned, and consoling the grieving.”
While bishops often argue in court filings that a priest’s contrition should weigh into sentencing, Warren said he believes a sentencing disparity between clerical and lay financial criminals could have potentially negative effects on the Church’s efforts to prevent financial crime.
“Sentences are supposed to deter the offender from reoffending, and to deter others in a similar situation from committing a similar offense because they would not want to incur a similar punishment,” he said. “If potential clergy offenders believe that they will receive lighter sentences than the public for similar bad conduct because of their clerical status, that may lessen the desired deterrent value of the punishment.”
Warren cited an example: “If a priest sees that a layman was sentenced to 57 months in prison for stealing $170,000 from a parish, he may think twice about stealing,” Warren said.
But, he elaborated, “if that same priest learns about a priest in the Diocese of Arlington, who stole a $1,000,000 from several parishes and was spared jail time, after his bishop wrote an impassioned letter claiming to the court that the loss of the offending priest's priesthood was punishment enough, then the potential priest offender may decide that getting probation and being allowed to retire to Florida on his full pension and no supervision isn't much of a deterrent.”
Darrey is expected to be sentenced in November.