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- In order to organize the research already done we are at a stage where we need to put together an organized database system that can be accessed as the knowledgebase of an AI LLM tool so we can pull out topic by topic and case by case quotes and derivitave work already completed and phrased properly for amicus briefs. Below is the conversation about the tools required.
- Micro-topics you can reuse: S.J. v. Choice Hotels Int’l, Inc., 473 F. Supp. 3d 147 (E.D.N.Y. 2020) – Praxis Professional
- Executive summary: In S.J. v. Choice Hotels Int’l, Inc., a trafficking survivor sued hotel franchisors (Choice, Wyndham, and Howard Johnson) and property owners, alleging they knowingly benefited from a sex-trafficking venture at branded motels and ignored obvious red flags. On a Rule 12(b)(6) motion, the Eastern District of New York dismissed the TVPRA §1595 and N.Y. Soc. Serv. Law §483-bb claims against the franchisors (including on retroactivity grounds for §483-bb), but allowed a state-law negligence claim to proceed, finding a plausible duty given the foreseeability of trafficking at brand properties and the franchisors’ own training/anti-trafficking commitments. The decision highlights detailed “red-flag” fact pleading (cash payments, numerous male visitors, refusal of housekeeping, condoms, staff misconduct) and preserves negligence as an alternate path even where TVPRA claims falter. Justia Law
- Doe v. Red Roof/Choice/Wyndham/Microtel – Praxis Professional
- Executive summary: In a consolidated Eleventh Circuit appeal, four trafficking survivors sued hotel franchisors (Choice, Wyndham, and Microtel) under TVPRA §1595 and Georgia law, alleging the brands benefited from and participated in sex-trafficking “ventures” at franchised properties. The court held—on a question of first impression—that a §1595 beneficiary claim requires plausibly alleging the defendant (1) knowingly benefited, (2) by taking part in a common undertaking involving risk and potential profit, (3) that undertaking violated the TVPRA as to the plaintiff, and (4) the defendant had actual or constructive knowledge of that violation; applying the statute’s plain meaning, the court declined to import the criminal §1591 definition of “participation in a venture.” Finding the pleadings did not tie the franchisors to participation in the specific trafficking ventures at issue, the court affirmed dismissal of the TVPRA and related state-law claims, including negligence, which failed absent allegations of franchisors’ day-to-day operational control or full knowledge sufficient for ratification.
- Red Flag Language – Praxis Professional
- “Red flag” language collects the concrete, property-level indicators courts recognize as warning signs of sex trafficking at hotels (e.g., cash, day-to-day extensions, heavy male foot traffic, condom debris, frequent linen changes, do-not-disturb for days, visible injuries, audible distress). In litigation—especially under TVPRA §1595 and parallel negligence claims—these passages are useful to (1) plead and argue constructive knowledge (“knew or should have known”), (2) show foreseeability and breach of basic duties (screening, training, escalation), (3) establish industry notice/standards and what reasonable staff would observe, and (4) defeat motions to dismiss or support summary judgment/opposition by tying specific facts at a budget hotel to judicially recognized indicia. They also guide policy and training exhibits by translating abstract duties into observable, documentable conditions.
