MDL Track
MDL 3104
S.D. Ohio
Institutional Abuse · claims that hotel operators ignored obvious signs of trafficking and profited from the abuse
Defendant
Wyndham Hotels & Resorts, Inc.
MDL / Track
MDL 3104
S.D. Ohio
Judge
Chief Judge Algenon L. Marbley
Plaintiffs
ACTIVE
Bellwether / Trial
$40M verdict for child trafficking victim against United Inn & Suites (N.D. Ga. July 2024)
Settlement Status
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Case overview
A wave of federal litigation under the Trafficking Victims Protection Reauthorization Act (TVPRA) targets hotel chains for allegedly enabling sex trafficking by ignoring overt warning signs. In December 2025, Andreozzi + Foote filed suit in the Harrisburg–Hershey region naming Holiday Inn Express, Best Western, Marriott properties, and others, alleging staff witnessed daily cash rentals, bruised victims, and trafficker surveillance yet continued renting rooms. This follows a confidential June 2024 settlement by Red Roof Inns mid-trial in the first hotel sex trafficking case to reach a jury, overseen by Judge Victoria Calvert in the Northern District of Georgia (case filed 2020). At least 42 federal lawsuits are pending against Red Roof Inn across 39 states, with hundreds more victims preparing claims.
Causation Theory
Hotels serve as operational infrastructure for trafficking ventures: analysis of 2018–2019 federal criminal sex trafficking cases found approximately 80% involved exploitation at hotels or motels (Jeng et al., Religions 2022). Traffickers exploit the hospitality industry's anonymity, transient clientele, and room-by-room rental model to create controlled environments for commercial sexual exploitation. Plaintiffs allege corporate defendants observed and ignored established indicators including cash payments for short-term stays, excessive linen requests, visible condoms and paraphernalia, victims showing bruising and malnourishment, trafficker surveillance of hallways, and online reviews flagging prostitution activity—yet failed to implement federally available training from DHS, ECPAT-USA, or the American Hotel & Lodging Association.
Case Management Orders
Litigation status
MDL No. 3104 (In re: Hotel Industry Sex Trafficking Litigation (No. II)) was created January 2024 and remains active before Chief Judge Algenon L. Marbley in the S.D. Ohio. The MDL succeeded after the JPML denied the first consolidation attempt (MDL 2928) in February 2020. Recent rulings continue to shape beneficiary liability theories under 18 U.S.C. §1595, with courts split on franchisor knowledge standards.
MDL Track
MDL 3104
S.D. Ohio
State Court Activity
Substantial parallel activity in state courts; 56,000+ cases referenced across MO, PA, GA, CA and other jurisdictions per industry reporting
Geographic exposure
Approximately 1,000 represented survivors in Red Roof Inn litigation alone; 115 properties across 39 states implicated. TVPRA claims proliferating against major chains including Wyndham, Choice, Hilton, Marriott, Hyatt, Best Western, Extended Stay America, InterContinental. MDL No. 2928 denied Feb. 5, 2020 (433 F. Supp. 3d 1353); cases proceeding in individual districts with varying SOL windows.
Red Roof Inn Corporate Plaza (Smyrna) and North Druid Hills Road (Atlanta). First sex trafficking lawsuit against national hotel brand to reach trial; settled mid-trial June 2024 with 11 plaintiffs. U.S. District Court for the Northern District of Georgia, Judge Victoria Calvert. Original complaint filed 2020. Evidence: open-air prostitution market, security guards partying with traffickers, 'NO REFUNDS AFTER 15 MINUTES' policy, excessive linen requests, used condom volumes.
In re Hotel TVPRA Litig., 35 cases consolidated for venue review before Magistrate Judge Elizabeth P. Deavers. April 25, 2023 order lifted stays; venue improper in S.D. Ohio for plaintiffs trafficked outside district. Cases transferred or dismissed for improper venue. Representative dockets: 2:22-cv-1924, 2:22-cv-2682, 2:22-cv-2690, 2:22-cv-2734, 2:22-cv-3080, 2:22-cv-3256, 2:22-cv-3258, 2:22-cv-3340, 2:22-cv-3416, 2:22-cv-3766 through 2:22-cv-3773, 2:22-cv-3774, 2:22-cv-3776, 2:22-cv-3778, 2:22-cv-3782, 2:22-cv-3784, 2:22-cv-3786, 2:22-cv-3787, 2:22-cv-3788, 2:22-cv-3797, 2:22-cv-3798, 2:22-cv-3799, 2:22-cv-3811, 2:22-cv-3837, 2:22-cv-3839, 2:22-cv-3842, 2:22-cv-3844, 2:22-cv-3845, 2:22-cv-3846.
J.M. v. Choice Hotels Int'l, No. 2:22-cv-00672-KJM-JDP (E.D. Cal. Oct. 17, 2022). Trafficking Feb.-Apr. 2012 at Stockton Rodeway Inn and Stockton Red Roof Inn. Plaintiff forced to solicit buyers in parking lot; staff witnessed pleas for help, bruises, cigarette burns. Court denied motion to dismiss TVPRA claim against franchisors Choice Hotels and Red Roof Inns.
Active litigation filed February 2026 in U.S. District Court in Baltimore. Seven Maryland hotels: Budget Inn (Pulaski Highway, Havre de Grace), Budget Inn (South Philadelphia Boulevard, Aberdeen), Days Inn (West Bel Air Avenue, Aberdeen), Super 8 (Beards Hill Road, Aberdeen), Travelodge (West Bel Air Avenue, Aberdeen), Motel 6 (Edgewood Road, Edgewood). Trafficking 2013-2016; Travelodge employee allegedly exploited victim's trafficked status for sex. One Pennsylvania hotel also named: Motel 6 (Arsenal Road, York).
The Independent investigation July 2024: 115 Red Roof Inn properties across 39 states named by survivors; 42+ federal lawsuits active. Attorney Steven Babin representing close to 1,000 victims. Customer reviews mention prostitution at 176 properties. Red Roof Inn operates approximately 624 U.S. properties.
Key defendants
Wyndham Hotels & Resorts, Inc.
Role: Franchisor
Motion to dismiss denied in T.S. v. Wyndham (D. Minn. 2024, Doc. 63) on beneficiary liability; joint employer theory survived in T.E. v. Wyndham (S.D. Ohio 2023, Doc. 35). Named in new W.D. Wash. filing (2:25-cv-00347, Feb. 2025). Losing ground on vicarious liability theories.
G6 Hospitality, LLC
Role: Franchisor
Dismissed from K.O. v. Red Lion (E.D. Mich. 2024, Doc. 135) on statute of limitations; refiled against in Doe v. G6 Hospitality (W.D. Wash. 2:25-cv-00347, Feb. 2025). Cyclical dismissal-and-refile pattern suggests plaintiffs treating as deep pocket despite temporal exposure limits.
Marriott International, Inc.
Role: Franchisor
Dismissed from K.O. (E.D. Mich. 2024, Doc. 135); survived dismissal in J.C. v. Choice Hotels (N.D. Cal. 2020, Doc. 104) on agency theory. Mixed record on personal jurisdiction and franchisee control—exposure varies by venue.
Choice Hotels International, Inc.
Role: Franchisor
Survived dismissal in J.C. (N.D. Cal. 2020, Doc. 104) on beneficiary and agency theories; opposed MDL 2928 centralization (J.P.M.L. 2020). Consistent litigation posture: challenge personal jurisdiction, deny operational control.
Red Roof Inns, Inc.
Role: Franchisor
Active in T.E. v. Wyndham (S.D. Ohio 2023, Doc. 35) alongside Wyndham; no reported dismissal order in that case. Recurring co-defendant in multi-hotel trafficking complaints.
| Defendant | Role | Intelligence Note |
|---|---|---|
| Wyndham Hotels & Resorts, Inc. | Franchisor | Motion to dismiss denied in T.S. v. Wyndham (D. Minn. 2024, Doc. 63) on beneficiary liability; joint employer theory survived in T.E. v. Wyndham (S.D. Ohio 2023, Doc. 35). Named in new W.D. Wash. filing (2:25-cv-00347, Feb. 2025). Losing ground on vicarious liability theories. |
| G6 Hospitality, LLC | Franchisor | Dismissed from K.O. v. Red Lion (E.D. Mich. 2024, Doc. 135) on statute of limitations; refiled against in Doe v. G6 Hospitality (W.D. Wash. 2:25-cv-00347, Feb. 2025). Cyclical dismissal-and-refile pattern suggests plaintiffs treating as deep pocket despite temporal exposure limits. |
| Marriott International, Inc. | Franchisor | Dismissed from K.O. (E.D. Mich. 2024, Doc. 135); survived dismissal in J.C. v. Choice Hotels (N.D. Cal. 2020, Doc. 104) on agency theory. Mixed record on personal jurisdiction and franchisee control—exposure varies by venue. |
| Choice Hotels International, Inc. | Franchisor | Survived dismissal in J.C. (N.D. Cal. 2020, Doc. 104) on beneficiary and agency theories; opposed MDL 2928 centralization (J.P.M.L. 2020). Consistent litigation posture: challenge personal jurisdiction, deny operational control. |
| Red Roof Inns, Inc. | Franchisor | Active in T.E. v. Wyndham (S.D. Ohio 2023, Doc. 35) alongside Wyndham; no reported dismissal order in that case. Recurring co-defendant in multi-hotel trafficking complaints. |
Timeline
TVPRA Civil Remedy Enacted
Congress amends Trafficking Victims Protection Reauthorization Act to create private right of action under 18 U.S.C. § 1595 allowing victims to sue entities that knowingly benefit from sex trafficking ventures.
JPML Denies Hotel MDL Formation
Judicial Panel on Multidistrict Litigation denies transfer motion for In re Hotel Industry Sex Trafficking Litigation, MDL No. 2928, finding insufficient common factual questions across 21 actions involving different hotels, brands, and trafficking ventures. 433 F.Supp.3d 1353 (J.P.M.L. 2020).
Marriott Franchisee Liability Pleadings Standard Set
E.D. Pa. denies Marriott's motion to dismiss in A.B. v. Marriott Int'l, Inc., 455 F.Supp.3d 171, holding plaintiff adequately pled franchisor liability under TVPRA by alleging corporate knowledge of trafficking indicators and failure to implement anti-trafficking policies. Civil Action No. 19-5770.
Red Roof Inn Settles Eve-of-Trial
Red Roof Inn settles TVPRA claims by four women alleging trafficking at Smyrna and Buckhead locations, days before scheduled trial in N.D. Ga. Terms undisclosed.
Red Roof Inn Mid-Trial Settlement
Red Roof Inn settles second Georgia TVPRA case mid-trial after plaintiffs complete evidence presentation. Eleven women alleged trafficking at same Smyrna and Buckhead properties from 2009-2018.
United Inn Dismissals
Two TVPRA cases against United Inn & Suites dismissed by N.D. Ga. federal judge; plaintiffs appeal. Dismissals preceded $40M verdict in related case.
$40M Verdict Against United Inn & Suites
Atlanta jury awards $10 million compensatory and $30 million punitive damages against United Inn & Suites in DeKalb County, first hotel TVPRA jury verdict in Georgia and largest civil trafficking award nationwide. Plaintiff trafficked at age 16. N.D. Ga.
Super 8 Trial Scheduled
Second Georgia hotel TVPRA trial scheduled against Super 8 in Tucker involving 15-year-old trafficked in 2015, following United Inn verdict.
Statute of limitations
TVPRA claims against hotels now carry substantial verdict exposure; equitable tolling doctrine expands federal filing windows when trafficking was ongoing. State law claims may provide longer or unlimited windows in Connecticut, Delaware, and California (post-2024). Screen for federal claims first where trafficking occurred at branded hotel properties.
California
7 years from date of being freed from trafficking (adults); 10 years from age 18 (minors)
Rule: Civil Code § 52.5; no civil SOL for child sexual abuse claims arising on or after January 1, 2024
Discovery: 10 years from discovery of psychological, physical, or emotional injury caused by trafficking
Cal. Code Civ. Proc. § 340.1 eliminates civil SOL for CSA claims on/after January 1, 2024
⚠Arkansas
2-year revival window: January 1, 2026 through December 31, 2027
Rule: Special revival statute for adult survivors; otherwise 3 years from incident or discovery for minors until age 21
Discovery: Clock starts from discovery of incident for minors
Revival window currently open for adult claims that would otherwise be time-barred; window closes December 31, 2027
New York
No criminal SOL for felony sex offenses; civil claims extended through discovery rule
Rule: Criminal SOL eliminated for rape and sexual abuse in 2006; civil claims benefit from discovery rule
Discovery: Discovery-based accrual for civil claims
Criminal prosecution available at any time for serious felonies; civil SOL until age 28 for child victims
Florida
No SOL if under 16 at time of incident; until age 25 if 16-17; 4 years for adults
Rule: No civil SOL for minors under 16; 10-year SOL for adult survivors for incidents on or after July 1, 2020
Age-based tiers create screening complexity; verify victim's age at time of trafficking
Connecticut
No civil statute of limitations
Rule: Complete elimination of civil SOL for sexual assault and abuse claims
Delaware
No civil statute of limitations
Rule: Complete elimination of civil SOL for sexual assault and abuse claims
Federal (TVPRA)
10 years from date of violation
Rule: 18 U.S.C. § 1595(c)(1); equitable tolling available per Doe v. Wyndham Hotels, No. 2:24-cv-204 (E.D. Va. March 6, 2025) (Walker, J.)
Discovery: Equitable tolling applies where trafficking ongoing; courts reluctant to dismiss at pleading stage
First TVPRA hotel jury verdict: $40 million against United Inn (2025); franchisor liability established
| State | SOL | Rule | Discovery Rule | Notes |
|---|---|---|---|---|
| California | 7 years from date of being freed from trafficking (adults); 10 years from age 18 (minors) | Civil Code § 52.5; no civil SOL for child sexual abuse claims arising on or after January 1, 2024 | 10 years from discovery of psychological, physical, or emotional injury caused by trafficking | Cal. Code Civ. Proc. § 340.1 eliminates civil SOL for CSA claims on/after January 1, 2024 |
| ⚠Arkansas | 2-year revival window: January 1, 2026 through December 31, 2027 | Special revival statute for adult survivors; otherwise 3 years from incident or discovery for minors until age 21 | Clock starts from discovery of incident for minors | Revival window currently open for adult claims that would otherwise be time-barred; window closes December 31, 2027 |
| New York | No criminal SOL for felony sex offenses; civil claims extended through discovery rule | Criminal SOL eliminated for rape and sexual abuse in 2006; civil claims benefit from discovery rule | Discovery-based accrual for civil claims | Criminal prosecution available at any time for serious felonies; civil SOL until age 28 for child victims |
| Florida | No SOL if under 16 at time of incident; until age 25 if 16-17; 4 years for adults | No civil SOL for minors under 16; 10-year SOL for adult survivors for incidents on or after July 1, 2020 | — | Age-based tiers create screening complexity; verify victim's age at time of trafficking |
| Connecticut | No civil statute of limitations | Complete elimination of civil SOL for sexual assault and abuse claims | — | — |
| Delaware | No civil statute of limitations | Complete elimination of civil SOL for sexual assault and abuse claims | — | — |
| Federal (TVPRA) | 10 years from date of violation | 18 U.S.C. § 1595(c)(1); equitable tolling available per Doe v. Wyndham Hotels, No. 2:24-cv-204 (E.D. Va. March 6, 2025) (Walker, J.) | Equitable tolling applies where trafficking ongoing; courts reluctant to dismiss at pleading stage | First TVPRA hotel jury verdict: $40 million against United Inn (2025); franchisor liability established |
Live intelligence
AI litigation brief
Sex Trafficking Hotel remains active mdl with 36 current signals in the accepted feed.
Overview
MDL No. 3104 (In re: Hotel Industry Sex Trafficking Litigation (No. II)) was created January 2024 and remains active before Chief Judge Algenon L. Marbley in the S.D. Ohio. The MDL succeeded after the JPML denied the first consolidation attempt (MDL 2928) in February 2020. Recent rulings continue to shape beneficiary liability theories under 18 U.S.C. §1595, with courts split on franchisor knowledge standards.
Key developments
Trajectory
Court filings and press coverage are both active in MDL 3104, pointing to sustained litigation pressure rather than a one-off headline cycle. 6 live sources are contributing current context.
Editorial intelligence
MDL 3104 should stay on the lead docket watch because it is the primary consolidation vehicle for Hotel Trafficking.
Generated Apr 28, 2026, 12:00 AM UTC
36 events detected
Google News (22)
DeKalb hotel ordered to pay $40 million in sex trafficking verdict - msn.com
Appeals court revives trafficking victims’ lawsuits against Atlanta-area hotels - 11Alive.com
DeKalb hotel at center of landmark sex trafficking ruling - AJC.com
Sex Trafficking Victims Get New Chance at Hotel Liability Claims - Bloomberg Law News
Lawsuit alleges SeaTac-area Motel 6 staff ignored signs of child sex trafficking - KING5.com
Lawsuit alleges SeaTac-area Motel 6 staff ignored signs of child sex trafficking - KING5.com
Liberty Mutual must pay hotel’s defense costs in sex trafficking cases - businessinsurance.com
Attorneys Announce Federal Lawsuit Against National Hotel Chain In Connection to Major Sex Trafficking Ring - EastTexasRadio.com
Woman sues Wyndham, other hotels over alleged connection to Houston sex trafficking - Houston Public Media
Texas lawsuit accuses major hotel chains of enabling sex trafficking - cbs19.tv
Woman sues Wyndham, other hotels over alleged connection to Houston sex trafficking - houstonpublicmedia.org
Texas lawsuit accuses major hotel chains of enabling sex trafficking - cbs19.tv
‘Protect our guests’: Sex trafficking victim sues Jacksonville hotel - Action News Jax
Jax hotel faces litigation years after sex trafficking bust - The Business Journals
Jax hotel faces litigation years after sex trafficking bust - The Business Journals
‘Protect our guests’: Sex trafficking victim sues Jacksonville hotel - Yahoo
Maryland hotels accused of enabling sex trafficking in lawsuit spanning 2013-16 - Baltimore Sun
Maryland hotels accused of enabling sex trafficking in lawsuit spanning 2013-16 - Baltimore Sun
Off-Strip resort-casino failed to prevent sex trafficking, lawsuit says - Las Vegas Review-Journal
Off-Strip resort-casino failed to prevent sex trafficking, lawsuit says - Las Vegas Review-Journal
Human Trafficking Liability Is No Longer Theoretical: TVPRA Exposure, Victim Remedies, and What Hotels Should Do Now - Foley & Lardner LLP
Human Trafficking Liability Is No Longer Theoretical: TVPRA Exposure, Victim Remedies, and What Hotels Should Do Now - Foley & Lardner LLP
No recent PubMed signals. Monitoring is active — this section updates automatically.
InterContinental Hotels Group Sex Trafficking Litigation
PACER docket entry from ILND: COMPLAINT filed by Jane Doe (K.R.D.), an Individual; Jury Demand. Filing fee $ 405, receipt number AILNDC-25021456. (Attachments: # 1 Civil Cover Sheet)(Harris, David) (Entered: 04/23/2026)
Red Roof Franchising LLC et al. Sex Trafficking Litigation
PACER docket entry from OHSD: COMPLAINT with JURY DEMAND against All Defendants ( Filing fee $ 405 paid - receipt number: AOHSDC-10998218), filed by JANE DOE (HT-00011). (Attachments: # 1 Civil Cover Sheet) (Barrick, Penny) (Entered: 04/21/2026)
G6 Hospitality et al. Sex Trafficking Litigation
PACER docket entry from OHSD: COMPLAINT with JURY DEMAND against All Defendants ( Filing fee $ 405 paid - receipt number: AOHSDC-10996978), filed by JANE DOE (HT-00009). (Attachments: # 1 Civil Cover Sheet) (Barrick, Penny) (Entered: 04/20/2026)
Delta Kew Holding Corp Sex Trafficking Litigation
PACER docket entry from OHSD: COMPLAINT with JURY DEMAND against All Defendants ( Filing fee $ 405 paid - receipt number: AOHSDC-10997455), filed by Jane Doe (HT-00010). (Attachments: # 1 Civil Cover Sheet) (Barrick, Penny) (Entered: 04/20/2026)
Teddy Bear Investments Sex Trafficking Litigation
PACER docket entry from MND: COMPLAINT against Teddy Bear Investments, LLP (filing fee $ 405, receipt number AMNDC-12890416) filed by Jane Doe (T.M.D.). Filer requests summons issued. (Attachments: # 1 Civil Cover Sheet) (Rick, Anna) (Entered: 04/17/2026)
Salesforce Sex Trafficking Litigation
PACER docket entry from CACD: COMPLAINT Receipt No: ACACDC-41955487 - Fee: $405, filed by plaintiff Jane Doe (SF-00015). (Attorney Mark D Potter added to party Jane Doe (SF-00015)(pty:pla))(Potter, Mark) (Entered: 04/09/2026)
Dhanuba Hospitality Inc. Sex Trafficking Litigation
PACER docket entry from CACD: COMPLAINT Receipt No: BCACDC-41949319 - Fee: $405, filed by Plaintiff Jane Doe. (Attorney Katie Llamas added to party Jane Doe(pty:pla))(Llamas, Katie) (Entered: 04/08/2026)
Starwood Hotels and Resorts Worldwide Sex Trafficking Litigation
PACER docket entry from MAD: COMPLAINT against Westin Operator LLC, Westin Hotel Management L.P., Host SH Boston Corporation, Starwood Hotels and Resorts Worldwide, LLC. Filing fee: $ 405, receipt number AMADC-11665542 (Fee Status: Filing Fee paid), filed by Hannah R.. (Attachments: # 1 Civil Cover Sheet, # 2 Category Form)(Do
Choice Hotels International Sex Trafficking Litigation
PACER docket entry from OHSD: COMPLAINT with JURY DEMAND against All Defendants ( Filing fee $ 405 paid - receipt number: AOHSDC-10978390), filed by Jane Doe (HT-00008). (Attachments: # 1 Civil Cover Sheet) (Barrick, Penny) (Entered: 04/08/2026)
Purple Rain Spa Sex Trafficking Litigation
PACER docket entry from CACD: COMPLAINT Receipt No: ACACDC-41886762 - Fee: $405, filed by Plaintiff K. L.. (Attorney Jeffrey C Toppe added to party K. L.(pty:pla))(Toppe, Jeffrey) (Entered: 04/01/2026)
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Court, news, and regulatory activity are elevated
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Last: Apr 28, 2026, 12:00 AM UTC
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AI Brief
Sex Trafficking Hotel remains active mdl with 36 current signals in the accepted feed.
Overview
MDL No. 3104 (In re: Hotel Industry Sex Trafficking Litigation (No. II)) was created January 2024 and remains active before Chief Judge Algenon L. Marbley in the S.D. Ohio. The MDL succeeded after the JPML denied the first consolidation attempt (MDL 2928) in February 2020. Recent rulings continue to shape beneficiary liability theories under 18 U.S.C. §1595, with courts split on franchisor knowledge standards.
Key developments
PACER court filing on Apr 23: InterContinental Hotels Group Sex Trafficking Litigation. ‖ msn.com news on Apr 23: DeKalb hotel ordered to pay $40 million in sex trafficking verdict - msn.com.
Generated Apr 28, 2026, 12:00 AM UTC
Tracked MDLs
MDL 3104
S.D. Ohio