Here are two credible, on-point amicus filings you can cite (both within 2020–present) that address hotel liability for sex-trafficking and “ignored red flags” (or are directly tied to that hotel-litigation stream):
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In re Hotel Industry Sex Trafficking Litigation (J.P.M.L.) — anti-trafficking orgs’ amicus briefs (2023)
When plaintiffs sought to centralize dozens of hotel sex-trafficking cases, the Judicial Panel noted multiple amicus briefs from anti-trafficking organizations addressing the common nucleus of facts—i.e., claims that franchisors/franchisees “knew or should have known” of trafficking based on persistent red-flag indicators at budget/franchised hotels. This isn’t a merits appeal, but it’s squarely about the same negligence/TVPRA hotel fact pattern and cites the amici filings head-on. See the JPML order (2nd round), which expressly references the amicus submissions. Case Law
- summary of the above: Result: The JPML denied centralization – Praxis Professional
- What the amici argued (summary) – Praxis Professional
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Wang v. Imperial Pacific International (9th Cir. 2022) — Human Trafficking Legal Center, Freedom Network USA, GLJ-ILRF, amicus brief
Although this brief arose in a labor-trafficking context (casino operator), it’s a recent, citable federal appellate amicus that lays out how courts should treat trafficking “red flags,” pleading burdens under the TVPRA, and why default/other sanctions must be available when defendants stonewall discovery—arguments that translate directly to hotel negligence/TVPRA cases (the same statute and “knew or should have known” frame often used against budget hotels). You can download the amicus PDF here. Freedom Network USA
If you’d like something even closer to a classic “budget hotel negligence” posture for your brief’s factual appendix, recent district decisions against franchisor/franchisee hotel defendants catalog the exact red flags (cash day-to-day payments for extended stays, heavy male foot-traffic, condom debris, visible injuries, lack of luggage, do-not-disturb for days, etc.). Two examples you can mine for those red-flag recitations (to support your amicus’s factual background section):
Summary Here (summaries of the below w/ red flag quotes and suggested amicus usage – Praxis Professional)
- A.M. v. Wyndham Hotels & Resorts, Inc. (M.D. Pa. 2024) — opinion discusses hotel-industry “red flags” and franchisor knowledge/should-have-known standards under TVPRA §1595. Courthouse News
- G.M. v. Choice Hotels International, Inc. (C.D. Cal. 2024) — addresses agency theories and plausibility against franchisors; useful for framing duty-of-care and corporate-level policy failures that allow red flags to persist at budget properties. Buchalter