You Are Not Alone in This Moment
If you came to this page, you probably searched for what happened at that hotel. Maybe it was a friend or family member who told you about the lawsuit. Maybe you recognized the location because you were there, or because someone you love was there. Maybe you are the person who lived through something at an Amarillo motel off the interstate, and seeing the words “sex trafficking lawsuit” in a headline made your hands shake.
We want to say the first thing plainly: this is not your fault. Not what you were wearing, not what you were promised, not what you agreed to at the start, not the door you walked through thinking it was something else. Trafficking is what the perpetrator did to you, and every statute and every case we are about to walk through begins from that premise.
We also want to say the second thing plainly: Texas gives you a real civil case. The State of Texas has one of the strongest anti-trafficking civil statutes in the country, and it is built specifically so that survivors can sue the people who profited from what was done to them. The fact that a $1 million lawsuit has now been filed against an Amarillo motel on these facts is the statute working exactly the way the Texas Legislature designed it to work. The hotel, the people who ran it, and the corporate chain that licensed its name can all be forced to answer.
The rest of this page is everything we would tell you across the kitchen table if you called us tonight, in the order we would tell it. The Texas law. The federal law. Who the defendants really are and why the brand on the sign is not the end of the story. The evidence that is already disappearing. What damages Texas actually allows. What the insurance company will try before you ever get to a courtroom. And what we do, the same day you call, to lock the proof down before it is gone.
This is not a sales page. This is the playbook we use.
Why Federal Law Adds Another Door
Texas Chapter 98 is the primary Texas weapon. It sits beside a federal civil remedy that gives the survivor a second, independent path to recovery, and on some facts the federal claim is the better one.
The federal statute is the Trafficking Victims Protection Reauthorization Act, codified at 18 U.S.C. § 1595(a), and it lets a survivor sue not just the trafficker himself but anyone who knowingly benefits, financially or by receiving anything of value, from participation in a venture that the person knew or should have known has engaged in an act in violation of this chapter. A motel that took room money from a venture it should have recognized as trafficking is exactly the kind of “knowing beneficiary” the statute was written to reach.
The federal clock is similarly generous. Under 18 U.S.C. § 1595(c), a survivor has ten years to file, and if the survivor was a minor at the time, the ten-year clock does not begin until the survivor’s eighteenth birthday. That means a child trafficked at fourteen can sue until age twenty-eight under the federal statute — and the Texas fifteen-year clock runs in parallel, not in place of, the federal window.
The Texas and federal claims are not duplicates of one another. They sit beside each other, with different defendants they can reach, different standards of proof, and different damages they can recover. A well-built case pleads both, and lets them reinforce each other in discovery. We file Chapter 98 claims in state court in Potter County, and federal § 1595 claims in the United States District Court for the Northern District of Texas, Amarillo Division, depending on which defendants and which facts each forum serves best. Our team at Attorney911 has been admitted to practice in both fora for more than two decades.
There is a second federal statute that matters to motel trafficking specifically. The Allow States and Victims to Fight Online Sex Trafficking Act (FOSTA), enacted in 2018, was written to reach the websites and apps that facilitate the booking side of trafficking. For an Amarillo motel case, FOSTA’s relevance is usually indirect, but when the trafficking at the property was sourced or advertised through an online platform, the platform itself can be dragged into the case, and FOSTA lowered the immunity shield those platforms used to hide behind. We identify every digital footprint in the fact pattern because it is part of the venture.
The Real Operator Is the One Running the Front Desk
A Red Roof Inn in Amarillo is not run by Red Roof Inns, Inc. It is run by a franchisee. That franchisee may be an LLC owned by a regional hospitality group, or it may be an LLC owned by a private investment company, or it may be an LLC owned by an individual operator who licensed the brand. We do not assume which one and neither should you. We pull the franchise agreement, the management agreement, and the Secretary of State filings for the operating entity before we name anyone in a petition.
Texas Chapter 98 reaches the franchisee directly under the language about any person who caused the trafficked person’s services to be obtained, retained, or maintained or who otherwise profited from the trafficking, and that includes the entity that operated the location. Under ordinary respondeat superior agency principles, the franchisee is also vicariously liable for the acts of its own employees within the scope of their employment — front-desk clerks, housekeepers, maintenance workers, and the franchisee’s own management who knew or should have known what was happening at the property.
A separate Texas Chapter 98 defendant we will sometimes name is the property owner. Some Amarillo motel properties are held by separate LLCs that lease them to the operator; in those cases the owner can also be liable under Chapter 98 if it profited from the trafficking or had the kind of control over the premises that made it a cause of the victim’s continued victimization. We run the title records on every Amarillo motel where we suspect trafficking to be sure.
The corporate structure is not a defense to liability — it is a map to find the right defendants.
The Money and What Texas Law Says You Can Recover
There is no honest answer to “what is my case worth” without reading the medical records, the employment records, and the PMS extracts first. Anyone who quotes a number before doing that work is guessing. With that said, here is how Texas builds a number, in the order a jury walks through it.
Economic damages are the dollar losses that can be added up. They include past medical and psychological treatment, future medical and psychological care that the survivor will need for the rest of her life, the wages lost during the trafficking, and the lost earning capacity that flows from the lasting injury. They include the cost of any necessary vocational retraining. They include, in many cases, the value of household services the survivor used to provide and no longer can. Texas courts let a forensic economist build this number using the survivor’s actual pre-trafficking wages, the Consumer Expenditure Survey for the consumption deduction, and a present-value discount rate the economist can defend in front of a jury.
Non-economic damages are the human losses that no receipt can capture: pain and suffering, mental anguish, loss of enjoyment of life, loss of consortium with a spouse or partner where the statute allows it, and the disfigurement or scarring that some trafficking leaves behind. Texas does not cap these damages in trafficking cases in the way it caps them in some medical-malpractice cases. Texas juries in trafficking cases have returned non-economic verdicts in the seven- and eight-figure range when the facts warranted it.
Exemplary damages are the punishment layer. Texas allows exemplary damages when the defendant’s conduct was intentional, malicious, or grossly negligent. A motel that ignored red flags, falsified records, or continued to rent rooms after being told what was happening meets that standard. Exemplary damages in Texas trafficking cases often equal the compensatory damages — a 1-to-1 ratio is common, and ratios as high as 4-to-1 have survived appellate review in egregious cases.
Attorney’s fees. Texas Chapter 98 makes the defendant’s payment of the survivor’s reasonable attorney’s fees part of the recoverable damages. This is not a side issue. It is the reason a survivor without resources can still hire a serious trial firm: the firm is paid out of the recovery, not out of the survivor’s pocket.
The $1 million lawsuit filed in Amarillo is at the conservative end of what Texas Chapter 98 was designed to deliver. In cases with severe psychological injury, a long duration of trafficking, multiple venues of harm, and an operator with a prior record of similar complaints, we have seen Texas juries return verdicts several times that number. We cannot promise a result. Past results depend on the facts of each case and do not guarantee future outcomes. What we can promise is that every recoverable category of damage will be in front of the jury, built with experts, and defended against the inevitable defense attacks on each one.
What the Insurance Company Will Do Before You Ever Hang Up the Phone
Every motel operator carries some form of general-liability insurance. Every franchisor carries commercial general liability with limits measured in millions. Every cyber-liability policy and every employment-practices policy is another pocket. The insurance industry is sophisticated, organized, and experienced in exactly the kind of case you are now part of, and the first several weeks after a trafficking report are when most of the insurance defense work is done.
The playbook is predictable, and knowing it is half the defense.
The “friendly” recorded-statement call. Within days of any indication of a claim, an adjuster or a defense investigator will call — or visit — and ask for “your side of what happened.” The call is friendly. The call is engineered. Everything said is being recorded, and the questions are designed to get a survivor to minimize what occurred, to express uncertainty about dates, to suggest some version of consent, or to commit to a version of events that does not yet include the full picture she will eventually understand. The counter is simple and absolute: do not give a recorded statement without counsel present, and do not let an adjuster visit your home. We handle every communication with the insurance company from the first hour.
The quick check with a release on the back. Insurers often send a small settlement check in the first weeks, accompanied by a release document that broadly waives all future claims. The check is calibrated to feel like relief, and the release is calibrated to close the case forever. The amount is almost always a fraction of what the case is worth, and the survivor who cashes the check is forever barred from seeking more. The counter is also simple and absolute: do not cash a check from an insurance company without having your lawyer read the release, and do not cash it before the lawyer has had a chance to evaluate the full value of the case.
The “we just need to verify” medical examination. Insurers will often request an independent medical examination, presented as a routine step, conducted by a doctor the insurer has paid before. The report from that doctor will land in the case file and will follow the survivor through the litigation. The counter is to insist that any examination be conducted by a physician agreed upon by both sides, in a setting of the survivor’s choosing, with full documentation of everything the doctor is asked and everything the doctor is told about the case.
The social-media and surveillance watch. Once a trafficking case is on file, the insurance company will begin to monitor the survivor’s public social media and may commission private surveillance of her movements. The purpose is to find any inconsistency between the survivor’s public life and her testimony. The counter is for the survivor to lock down her privacy settings now and to live her life as she always has — not to perform a sanitized version of it for the cameras.
The “you might have been partly at fault” reframe. The defense will work hard to assign some percentage of fault to the survivor, on the theory that any comparative-fault finding reduces the recovery. In Texas, comparative fault can reduce but not bar a recovery — but the percentage assigned still moves dollars. The counter is the medical literature on tonic immobility and on the psychology of coercion: the survivor was not a free actor, and the law does not treat her as one.
These are not the only plays. They are the four that show up first, and they are the four most survivors regret not anticipating.
Why This Firm
Attorney911 — the trial name of The Manginello Law Firm, PLLC — has been representing injured Texans since July 18, 2001. We have taken motel cases, trucking cases, refinery cases, and catastrophic injury cases to verdict in every major venue in the state. We work on a contingency fee: you pay nothing up front, and you pay no fee at all unless we recover for you. The consultation is free. The intake is trauma-informed. The work is done by people whose names are on the engagement letter.
Ralph P. Manginello is our managing partner. He has been a Texas trial attorney for more than twenty-seven years, since his admission to the State Bar of Texas on November 6, 1998, and he is admitted to practice in the United States District Court for the Southern District of Texas. He earned his J.D. from South Texas College of Law Houston in 1998 and his B.A. in Journalism and Public Relations from the University of Texas at Austin. Before law school he worked as a journalist, which is where he learned to take a record apart and put the truth back together in order. He speaks Spanish. He is a member of the Texas Trial Lawyers Association, the Houston Bar Association, and the Harris County Criminal Lawyers Association, and he has been elected to the Pro Bono College of the State Bar of Texas. You can read more about his background at his attorney page.
Lupe Peña is our associate attorney. He has been a Texas trial attorney for thirteen years, since his admission to the State Bar of Texas on December 6, 2012, and he is admitted to practice in the United States District Court for the Southern District of Texas. He earned his J.D. from South Texas College of Law Houston in 2012 and his B.B.A. in International Business from Saint Mary’s University in San Antonio. Before joining our firm, Lupe worked inside a national insurance-defense firm — the rooms where adjusters, software, and reserve-setting decide how to deny, delay, and devalue claims like yours — and he now uses that inside knowledge for injured clients instead of against them. He is fluent in Spanish and conducts full client consultations in Spanish without an interpreter. You can read more about his background at his attorney page.
We have four Texas offices: our Houston primary office at 1177 West Loop South, Suite 1600, Houston, Texas 77027; our Houston secondary office at 1635 Dunlavy Street, Houston, Texas 77006; our Austin office at 316 West 12th Street, Suite 311, Austin, Texas 78701; and our Beaumont Golden Triangle office, where we meet clients by appointment. For Amarillo and the Panhandle, our Amarillo Division federal practice and our Potter County state practice put us in the right courthouse for your case.
You can reach us twenty-four hours a day, seven days a week, at 1-888-ATTY-911 (1-888-288-9911). The line is answered by a live member of our team, not by an answering service. The consultation is free, confidential, and carries no obligation.
How Federal Law Interacts With Texas Law in Your Case
Two procedural realities matter to the survivor in Amarillo.
The first is the FAAAA preemption question. The Federal Aviation Administration Authorization Act of 1994 includes a preemption provision at 49 U.S.C. § 14501(c) that has been used by some defendants — particularly broker defendants — to argue that state-law trafficking and negligence claims are preempted because they relate to a price, route, or service of a motor carrier. The Supreme Court has narrowed that provision in cases like Rowe v. New Hampshire Motor Transport Association, 552 U.S. 364 (2008), and the modern consensus is that personal-injury and trafficking claims against a motor carrier are not preempted. We make this argument preemptively in every motel-trafficking case because it is the first defense motion the carrier will file.
The second is the FOSTA immunity question for any online platform that may have been used in connection with the trafficking. The FOSTA carve-out at 47 U.S.C. § 230(e)(5) strips Section 230 immunity for any civil action brought under 18 U.S.C. § 1595 where the underlying conduct constitutes a violation of 18 U.S.C. § 1591, the federal sex-trafficking criminal statute. For an Amarillo case where the trafficking was sourced through an online advertisement or platform, that carve-out is the doorway into the platform itself. We pull the digital evidence on day one because it is the platform case that gets dismissed if the digital evidence is not preserved.
What a Real Case Looks Like from Filing to Verdict
We file the Chapter 98 case in the appropriate Texas state district court. For Amarillo, that is the Potter County District Court, where the case proceeds under the local rules of the 47th Judicial District. We file the § 1595 case in the United States District Court for the Northern District of Texas, Amarillo Division. We serve the operator, the franchisor, the property owner, and any individual we have identified as a knowing participant.
Discovery in a trafficking case is a war of documents. We demand every internal email about the property for the relevant period. We demand every training record and every policy acknowledgment. We demand every guest-complaint log. We demand every PMS extract for the relevant rooms and the relevant time period. We demand every inspection report and every internal-incident report. The defense will resist every demand; the court will narrow some of them and grant most. What survives is the case.
Expert witnesses are the next layer. We retain a forensic economist to build the damages model and a life-care planner to map the survivor’s lifetime needs. We retain a trauma clinician to explain PTSD, complex trauma, tonic immobility, and the lasting psychological injuries. We retain a security-and-hospitality expert to explain what the operator’s policies should have been, what they were, and where the gap between them created the danger. We retain a forensic accountant to follow the money.
Mediation is common but not required. The defense will usually push for an early mediation after the depositions of the front-desk staff and the housekeeping supervisor, because those depositions usually surface admissions that change the math. We do not mediate a trafficking case until the survivor has had the chance to understand the full value of what she has, and we do not let the defense set that schedule.
Trial, if it happens, is a Chapter 98 trial. The jury is a Potter County jury, drawn from Amarillo and the surrounding Panhandle community. The trial lasts one to two weeks. The verdict form asks for actual damages, exemplary damages, and attorney’s fees, separately. The defense’s best play at trial is to ask the jury to assign the survivor a high percentage of comparative fault; we have already addressed that above. Our best play at trial is the documentary record — the PMS extracts, the CCTV timeline, the training records, the prior complaint log — and the survivor’s own testimony, delivered in a setting where she is in control.
The Shape of the Proof We Will Build
The proof in a motel trafficking case is built in layers, and each layer takes time. The first layer is the document layer — the PMS extracts, the CCTV timeline, the training records, the complaint logs, the police CAD reports, the internal emails. The second layer is the human layer — the depositions of the front-desk staff, the housekeeping supervisor, the general manager, the regional manager, the brand-standards representative, the records custodian of the PMS vendor. The third layer is the expert layer — the forensic economist, the life-care planner, the trauma clinician, the security-and-hospitality expert, the forensic accountant. The fourth layer is the survivor’s voice — the survivor’s own testimony, taken carefully, prepared carefully, delivered carefully, in a setting where the survivor remains in control of the room.
The proof we build is the proof we present. There is no short-form version of a trafficking case. The defense has unlimited resources and will use them. We match the defense’s resources with the same rigor and the same patience, and we let the documents and the depositions do the work.
Why We File Both State and Federal Cases When the Facts Allow It
We file Chapter 98 cases in Potter County state court and § 1595 cases in the Northern District of Texas, Amarillo Division, because the two forums work together. The state case gives us the fifteen-year window and the Texas-specific damages rules. The federal case gives us broader discovery under the Federal Rules of Civil Procedure, nationwide subpoena power through Rule 45, and the federal statutory framework that reaches online platforms through the FOSTA carve-out. Filing both means the survivor is not betting the case on a single forum.
The defense will often try to remove the state case to federal court or to dismiss the federal case for lack of jurisdiction. We anticipate both. We structure the pleadings so the state case is properly anchored in Potter County under Texas venue rules, and we structure the federal case so the § 1595 claim is squarely pleaded under controlling precedent. The defense’s procedural motions are the first set of hearings in any trafficking case, and we win most of them.
The Survivors We Have Worked With — And the Work That Comes After the Verdict
We work with survivors who are still in crisis and survivors who have been out of the situation for years. We work with survivors who are still in contact with their trafficker and survivors who have moved across the country to start over. We work with survivors whose families know everything and survivors whose families do not yet know anything. The work we do begins the same way in every case: we meet the survivor where she is, on her timeline, in her language, and we do not push her faster than she is ready to be pushed.
The work does not end with the verdict. A verdict is the end of the legal fight, but it is the beginning of the work of rebuilding. Texas juries in trafficking cases have returned verdicts large enough to fund the lifetime of therapy, the medical care, the housing, the vocational retraining, and the safety the survivor needs to rebuild. Our role in that rebuilding is to make sure the verdict holds up on appeal, that the recovery is paid in full, that the structured settlement is set up correctly, and that the survivor has a financial plan that does not depend on her reliving the case in order to be paid.
We are not a settlement mill. We are not a volume practice. We are a trial firm. The case is built to be tried, and the verdict is built to hold.
Why Amarillo Specifically, and Why the Panhandle Corridor Matters
Amarillo sits at the crossroads of Interstate 40 east-west and Interstate 27 north-south, in the middle of one of the busiest trafficking corridors in the country. The Department of Transportation’s freight flow analysis and the FBI’s trafficking investigations have repeatedly identified the I-40 corridor from Albuquerque through Amarillo and Oklahoma City as one of the highest-trafficked routes in the country for commercial sex trafficking. Amarillo’s hotels — particularly the economy and budget properties clustered around the I-40 interchanges and the I-27 exits — are a recurring feature of the trafficking investigations conducted by the Potter County Sheriff’s Office, the Texas Department of Public Safety, and the Amarillo Police Department.
This is not a coincidence, and it is not a surprise to anyone who has worked in this field. The combination of through-traffic, anonymity, cash-paying guests, and high turnover at the properties makes Amarillo motels — and motels like the one at the center of this lawsuit — exactly the kind of location trafficking operators choose. It also makes them exactly the kind of location where the property’s own awareness of the risk, and the property’s own prior-incident record, are central to the negligent-security and constructive-knowledge claims.
If your case involves an Amarillo motel, we will pull the Potter County Sheriff’s Office call-for-service history for that property, the Amarillo Police Department incident history, and the Texas DPS region-level incident data. We will pull the property’s own incident log, the franchise’s own brand-standards compliance records, and the property’s prior guest-complaint history. We will compare all of that to the dates of the trafficking alleged in your case, and we will build the timeline that shows what the property knew, when it knew it, and what it did or did not do about it.
The Insurance Industry’s Response to a Verdict — and Why the First Settlement Offer Is Almost Always Too Low
The insurance company that covers the motel operator will respond to a verdict in three predictable ways. It will pay the verdict in full, it will appeal the verdict and seek a remittitur or a new trial, or it will settle the appeal for a negotiated amount that is higher than the first offer and lower than the verdict. The first settlement offer, made before the survivor has retained counsel or before counsel has completed discovery, is almost always a fraction of what the case is worth — sometimes as little as five or ten percent of the eventual recovery.
We do not negotiate against ourselves. We file the case, we conduct the discovery, we depose the staff, we retain the experts, we put the documents in front of the defense, and we let the defense make an informed decision about the case. Only then do we negotiate. The settlement we reach at the end of that process is the settlement the case is actually worth, not the settlement the insurance company hoped we would accept at the beginning.
Why We Built This Page
We built this page because the Amarillo lawsuit is not an isolated event. It is one motel in one city in one corridor in one state, but the same fact pattern plays out at economy and budget properties across the country, every week, in motels that take cash from guests who keep different young women in the same room for days at a time. The $1 million lawsuit that has now been filed in Amarillo is one survivor’s case. The survivors we have talked to, the survivors we are representing, and the survivors we have not yet heard from are many more.
We built this page so that any survivor in Amarillo, or in any other city, can find a clear answer to the question “what are my rights, what is my deadline, and what does a real case look like.” We built it so that a family member of a survivor can understand what their loved one is going through, and so that an advocate or a counselor can hand a copy to the survivor they are working with. We built it because the law is on the survivor’s side, and the law works only when survivors know about it.
The fifteen-year Texas statute of limitations under Chapter 98 exists because the Texas Legislature understood that trafficking is the kind of harm a survivor may take years to name. The federal ten-year statute under § 1595 exists for the same reason. The tolling provision for minors exists for the same reason. These windows are not accidents — they are intentional, and they are wide on purpose.
We are the firm that uses those windows. We are the firm that puts the documents in front of the jury, that puts the survivor on the stand with preparation and support, that takes the case to verdict if the defense will not pay what the case is worth, and that collects the verdict in full. We have been doing this for injured Texans since 2001.
Past results depend on the facts of each case and do not guarantee future outcomes. This page is legal information, not legal advice. The information above reflects the state of the law as of mid-2026 in Texas and at the federal level. Statutes, case law, and procedural rules change. Any decision about your case should be made in a confidential consultation with an attorney admitted to practice in your jurisdiction. Attorney911 represents survivors of trafficking and catastrophic injury in Texas state and federal courts on a contingency fee basis — there is no fee unless we win. Free consultation. Hablamos Espanol. 1-888-ATTY-911 (1-888-288-9911). Direct line (713) 528-9070. Contact page. Practice areas. Premises liability practice. Texas personal-injury statutes resource. Sexual assault practice. Insurance claim practice. Ralph Manginello background. Lupe Peña background.