Introduction
The federal case S.J. v. Choice Hotels Int’l, Inc. (E.D.N.Y. 2020) is one of the most closely watched hotel trafficking lawsuits. While the court dismissed statutory claims under the TVPRA and New York’s § 483-bb, it allowed a direct negligence claim to move forward against franchisors such as Choice Hotels and Wyndham.
This article summarizes what happened after that ruling, traces the proceedings, and explains why the case ended the way many civil suits do — through a confidential settlement signaled by a stipulation of discontinuance with prejudice.
Surviving the Motion to Dismiss (2020)
In July 2020, Judge Eric Komitee dismissed the federal and state statutory claims against the franchisors. However, the court recognized that foreseeability of sex trafficking in hotels and the franchisors’ own public statements about safety supported allowing a direct negligence claim to proceed.
This meant the case stayed alive but was narrowed to one cause of action: negligence.
Amended Pleadings and Discovery (2020–2022)
Over the next two years, the litigation focused on:
- Refining the negligence claim through amended pleadings.
- Conducting discovery — exchanging documents, deposing witnesses, and preparing expert testimony.
- Addressing timeliness issues through New York’s Child Victims Act, which created a special window for older claims.
In February 2022, the magistrate judge recommended allowing the plaintiff to file a Third Amended Complaint, strengthening the negligence theory.
No Summary Judgment or Trial
Unlike some other hotel trafficking suits, S.J. never reached a published summary judgment ruling or trial. There are no court opinions testing whether the negligence evidence was sufficient to go to a jury.
Instead, the case proceeded through discovery and motion practice until mid-2022.
Stipulation of Discontinuance with Prejudice (July 2022)
On July 19, 2022, the parties filed a Stipulation of Discontinuance with Prejudice. The next day, the district court signed off, officially closing the case.
This procedural step means:
- The plaintiff cannot refile the claims.
- The case ends without a judicial ruling on the merits.
- Each side likely bore its own costs.
- The filing almost certainly reflects a confidential settlement, since that is the standard reason for voluntarily ending a case “with prejudice.”
Why This Looks Like a Settlement
In federal practice, settlements almost always appear on the docket as a stipulation of dismissal or discontinuance. These are typically one-page filings signed by attorneys and “So Ordered” by the judge. No dollar amounts or terms are revealed unless separately announced.
That is exactly what happened in S.J. v. Choice Hotels. The surviving negligence claim never went to trial. Instead, the case ended in a manner that strongly suggests a private settlement.
Timeline of Key Events
- July 22, 2020 — District court dismisses TVPRA and § 483-bb claims, but allows direct negligence claim to proceed.
- 2020–2021 — Amended pleadings and discovery process.
- February 2022 — Magistrate judge recommends granting leave to file a Third Amended Complaint, relying on the Child Victims Act.
- July 19, 2022 — Parties file a Stipulation of Discontinuance with Prejudice.
- July 20, 2022 — Court orders the case closed.
Conclusion
While S.J. v. Choice Hotels raised significant questions about franchisor liability for trafficking on hotel premises, the case did not produce a trial verdict. Instead, it followed a familiar trajectory: initial survival of a negligence claim, years of discovery, and ultimately a confidential settlement reflected in a stipulation of discontinuance with prejudice.