Doe v. Choice Hotels International, Inc., No. 20-11764 (11th Cir. 2021)
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Plaintiffs, four sex trafficking victims, filed suit against numerous defendants within the hotel industry for violations of the Trafficking Victims Protection Reauthorization Act (TVPRA), specifically 18 U.S.C. 1595(a), and Georgia state law. The district court held that plaintiffs failed to plausibly allege claims against three hotel franchisors: Choice Hotels, Wyndham Hotels, and Microtel Inn & Suites.
The Eleventh Circuit affirmed and held that Section 1595(a) should be applied according to its plain meaning: that is, to state a claim for beneficiary liability under the TVPRA, a plaintiff must plausibly allege that the defendant (1) knowingly benefited (2) from taking part in a common undertaking or enterprise involving risk and potential profit, (3) that the undertaking or enterprise violated the TVPRA as to the plaintiff, and (4) that the defendant had constructive or actual knowledge that the undertaking or enterprise violated the TVPRA as to the plaintiff. The court concluded that plaintiffs have failed to meet that burden as to the three franchisors at issue on appeal. The court likewise concluded that, as to these three defendants, plaintiffs did not state a plausible claim under Georgia state law.
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