Background
Two minor females, A.G. and G.W., were sex trafficked through hotels in Atlanta, Georgia. Their traffickers returned to the United Inn and Suites, owned by Northbrook Industries, Inc., three times. The traffickers spent time at the front desk, and an employee re-admitted the minors to their room without identification or reservation names. A third minor, C.B., was trafficked at The Hilltop Inn, owned by Naseeb Investments, Inc., where the owner accommodated the trafficker’s requests to avoid cleaning rooms. Summary judgment was granted for the hotel operators in all three actions.
The court’s reasoning
The court clarified that a civil beneficiary claim under the Trafficking Victims Protection Reauthorization Act requires proof that the defendant knowingly participated in a venture involving sex trafficking. Viewing facts in the light most favorable to the plaintiffs, the evidence showed that the hotels had knowledge of trafficking activities, failed to post required anti-trafficking notices, and their employees facilitated the traffickers’ operations. The district court erred in granting summary judgment because the plaintiffs presented sufficient evidence to allow a jury to find participation.
Because A.G., G.W., and C.B. each provided sufficient evidence to get to a jury on their claims, we vacate and remand.
Opinion of the Court, Page 2
What it means going forward
Hotel operators may face civil liability under the TVPRA if they knowingly participate in trafficking ventures, even if they did not directly commit the trafficking acts.