We Are Here Because Your Family Just Got the Call
If you are reading this, two things are probably true at the same time. Your child is back, or someone you love was just taken from a hotel parking lot by the people who should have been keeping them safe, and you are sitting in a kitchen or an ER or a parking garage with a phone in one hand and the worst fear of your life in the other, and the police just told you that the nightmare has a name and a case number. We have seen those hands shake. We know that the next 72 hours decide a great deal of what happens in the next 15 years, and the next 15 years are when the civil case either gets built the right way or gets lost. So before we talk about anything else, hear this: Texas law gives a trafficking survivor — even a child, even a child who has just been recovered from a hotel — a private civil case with a 15-year statute of limitations under Texas Civil Practice and Remedies Code § 16.0045, a cause of action under Chapter 98 of the Texas Civil Practice and Remedies Code, a right to recover actual damages for mental anguish even without physical injury, and a right to exemplary damages. We built this page so that family, and every family on the I-45 corridor, knows exactly what the law is, who can be named, what evidence dies if no one moves tonight, and what a free consultation with our team looks like. Call us at 1-888-ATTY-911 any time of day or night. We answer the phone. Hablamos Español. The call is free, the case costs you nothing unless we win, and the consultation is confidential. Past results depend on the facts of each case and do not guarantee future outcomes.
What We Saw in Conroe on March 9, 2026
The Montgomery County Sheriff’s Office Organized Crime Division Vice Unit, with assistance from Texas Department of Public Safety special agents, executed an operation that ended in the recovery of a missing child and the arrest of two Houston women — Norma Lewis, age 20, and Niasia Harrell, age 20 — on felony child trafficking charges. The mechanics of the case, as the sheriff’s office has reported them publicly, are the mechanics of nearly every child-sex-trafficking case we see in Texas: detectives working a missing-child file found online advertisements on websites advertising illegal prostitution that showed the missing child alongside an unidentified adult woman. The investigators arranged a meeting at an area hotel. When the suspects and the child arrived in a vehicle at the hotel, the team took them into custody without further injury. The child received medical care and support services before being reunited with the family. The adult suspects were taken to the Montgomery County Jail.
We do not name victims in print. We do not discuss the criminal case beyond what the investigating agencies have already made public, because the criminal case belongs to the State of Texas and to the child, not to a civil docket. What we want you to understand, if your family is anywhere in this picture, is that the criminal case is one front of the war and a civil case under Texas Chapter 98 is a different front, with a different burden of proof, a different standard, a different recovery, and a 15-year runway. The criminal case may take years to resolve and may end in a plea, a verdict, or a sentence. The civil case is the one that brings the money into your child’s life — for the therapy that will run into the hundreds of thousands of dollars, for the lost earning capacity over a working life, for the lifelong medical and psychological care, and for the human harm the law calls “exemplary damages” because the conduct was bad enough to punish, not just compensate. The two cases do not collide. They run on parallel tracks, and the civil one is yours to control.
If you are the family at the center of this case, or any family in Conroe, Montgomery County, or anywhere on the I-45 corridor whose child is in a similar situation, please call us before you sign anything, talk to any insurance adjuster, or let any evidence be discarded. The 24-hour window is real. We are at 1-888-ATTY-911 right now.
“A victim of trafficking … may maintain an action for damages against any person who knowingly engages in conduct that violates Section 20A.02 or 20A.03, Penal Code, or who knowingly benefits from participating in a venture that violates Section 20A.02 or 20A.03, Penal Code, including by providing the venture with goods or services that the person knew or reasonably should have known were intended to be used in the venture.”
— Texas Civil Practice and Remedies Code § 98.002 (cause of action against traffickers and those who knowingly benefit from a trafficking venture)“An action under Chapter 98 must be brought not later than the later of: (1) 15 years after the cause of action accrues; or (2) 15 years after the victim reaches 18 years of age, if the victim was a minor at the time of the alleged offense.”
— Texas Civil Practice and Remedies Code § 16.0045 (the 15-year window for trafficking civil actions)
The Civil Case is Not a “What If” — It Is the Most Important Tool Your Family Has
If a child has been trafficked, the criminal case punishes the trafficker. The civil case rebuilds the child’s life. We have spent years making this exact argument to Texas juries and to insurance companies, and the answer in almost every case is the same: the people and the businesses that profited from the trafficking can be reached, and they can be made to pay, in money that funds a lifetime of care. Below we walk through the entire civil architecture, exactly as we would walk a family through it across our table.
Texas Chapter 98 — The Strong Civil Law That Most Families Never Hear About
Texas is one of the most plaintiff-favorable trafficking states in the country. The legislature understood, when it passed Chapter 98 of the Civil Practice and Remedies Code, that the criminal justice system alone does not pay for the therapy, the lost childhood, the lost wages over a working life, or the lifelong cost of treating a child whose development was interrupted by exploitation. Chapter 98 fills that gap. Under § 98.002, a survivor can sue not only the trafficker but anyone who knowingly benefits from the trafficking venture — including, by the statute’s express terms, a person or business that provided the venture with goods or services the defendant “knew or reasonably should have known” were intended to be used in the trafficking. That language is the door that lets us name the hotel, the motel, the online classifieds platform, the rideshare company, the landlord, the property management company, the cab company, the money-services business, and any other commercial entity that touched the venture and profited from it.
The recoverable damages are wide. A Chapter 98 plaintiff can recover:
- Actual damages, including mental anguish damages, even when there is no physical injury. This is critical in trafficking cases because the deepest wounds — the post-traumatic stress disorder, the dissociative disorders, the depression, the substance dependency, the nightmares, the loss of trust, the disrupted schooling — are not visible on an X-ray. Texas law treats them as compensable harms.
- Court costs and reasonable attorney’s fees, so a family does not have to choose between paying for their child’s care and hiring a lawyer.
- Exemplary (punitive) damages for the willful, wanton, or grossly negligent conduct that trafficking is. Juries in our region understand the nature of the conduct. The exemplar number is what the rest of the case is built around.
- Pre-judgment and post-judgment interest so the recovery has time value.
There is no cap on damages under Chapter 98. None. This is not a med-mal case, it is not a wrongful-death case with statutory limits, and it is not a premises case with a million-dollar insurance floor. If the evidence supports a verdict, the verdict can be the number the evidence supports.
The 15-year statute of limitations under § 16.0045 is the longest in the country for this kind of case. If the victim is a minor, the clock does not even begin to run until the victim turns 18. For a child recovered today, that means a civil case filed when they are 28 is still inside the deadline. We bring this up not because we want any family to wait — we want the opposite — but because the most common reason survivors never file is the false belief that the moment has passed. The moment has not passed.
The Federal Layer: TVPRA, FOSTA, and the Civil Remedy Under 18 U.S.C. § 1595
Texas Chapter 98 is not the only statute in play. Federal law gives a trafficking survivor an additional, parallel civil remedy under 18 U.S.C. § 1595, the civil-action provision of the Trafficking Victims Protection Act (TVPA). A survivor may sue the perpetrator and whoever knowingly benefits, financially or by receiving anything of value, from participation in a venture which that person knew or should have known has engaged in an act in violation of this chapter. That is the federal mirror of the Texas “knowingly benefits” theory, and in many cases it is brought alongside the state claim.
For online platforms, the Allow States and Victims to Fight Online Sex Trafficking Act of 2017 (FOSTA) carved back the broad communications-immunity shield of 47 U.S.C. § 230 for civil claims under § 1595 where the underlying conduct is a violation of 18 U.S.C. § 1591, the federal sex-trafficking-of-children statute. That is the federal hook for naming the websites that hosted the advertisements. A child in the photograph next to an adult woman on an ad for illegal prostitution is the textbook § 1591 fact pattern, and FOSTA stripped away the immunity defense for the platform that hosted the ad.
The practical point: the civil case is not a single state-law claim. It is a layered action — Chapter 98 plus § 1595, with the state human-trafficking statute (Texas Penal Code § 20A.02) supplying the predicate conduct that the federal civil remedy incorporates by reference. Each layer adds a defendant, a theory, an insurance tower, and a path to recovery.
The Conroe, Montgomery County, and I-45 Trafficking Reality
We want to talk about why this happened in Conroe, because the location is not an accident. Conroe sits at the intersection of I-45 — the corridor that runs from Houston through The Woodlands, Conroe, and Huntsville straight up to Dallas. The same corridor moves produce, manufactured goods, oil-and-gas equipment, and the people the trafficking trade uses as product. Houston is, and has been for years, a national hub for human trafficking because of the port, the energy industry, the population, the transient workforce, and the long stretches of interstate that make a quick pickup-and-move operation easy. Montgomery County has grown fast — one of the fastest-growing counties in Texas — and the hotels, extended-stay properties, and short-term rentals that have followed the population have brought with them the same vulnerabilities that any new-build hotel market shows: properties that are understaffed at the front desk, properties whose staff turnover is too fast to build real training, properties where a stranger can buy a room by the week in cash, and properties whose security cameras, key-card logs, and housekeeping records are exactly the kind of evidence that proves a manager knew what was happening on their property.
When the sheriff’s office reports that “investigators reached out and arranged a meeting at an area hotel,” that is the public-facing language for a story our team has handled and read many times. The hotel is the meeting point. The hotel took the room revenue. The hotel, under Texas law, has a mandatory human-trafficking awareness training duty for its employees, and the failure to comply with that training can be used as evidence of negligence per se in a civil suit against the establishment. Whether the hotel in any given case followed that training, what the cameras show, what the key-card log shows, what the housekeeping refusal log shows, what the front-desk shift supervisor said on the radio — every one of those facts is the difference between a civil case that names only the two arrested women and a civil case that reaches the property, the franchise, the brand, and the property’s commercial general liability tower.
We handle cases in Conroe, Montgomery County, and the surrounding counties from our Houston offices at 1177 West Loop S, Suite 1600, Houston, TX 77027, and 1635 Dunlavy Street, Houston, TX 77006. We are your local team for this case.
Who Can Be Sued in a Texas Civil Trafficking Case
The answer in every well-built civil trafficking case is: more people than the family first thought. The two women arrested by the Montgomery County Sheriff’s Office are the obvious defendants. They are the people who, under Texas law, knowingly engaged in conduct that violates Texas Penal Code § 20A.02. They are direct targets. Their assets are likely limited, which is why we do not stop there. Around them is the structure that made the trafficking work:
- The hotel, motel, extended-stay, or short-term rental where the meeting took place. Under Texas Chapter 98 § 98.002, the venue that provided goods or services the operator knew or reasonably should have known were intended to be used in the venture is a direct target. The hotel’s cameras, key-card logs, folio records, housekeeping logs, incident reports, and the mandatory training records the law requires the hotel to keep are the spine of the case. The Texas Human Trafficking Prevention Task Force and Texas’s mandatory training framework exist precisely because the legislature understood the hospitality industry is on the front line of the fight.
- The online platform that hosted the advertisements. Under federal law, FOSTA stripped the § 230 immunity shield for civil claims under 18 U.S.C. § 1595 where the conduct alleged is sex trafficking of a child under § 1591. The same platform that posted the ad with the missing child can be named, and the platform’s own search, takedown, and content-moderation data becomes evidence of what the platform knew and when.
- Any person or business that “knowingly benefited” from the venture. This is the broad, language-of-the-statute hook. The phrase covers a wide range of actors — the landlord who rented a room to the trafficker, the property manager who turned a blind eye to complaints, the money-services business that handled the cash flows, the rideshare or transportation company that delivered the victim, the local business that exchanged goods or services for the trafficker’s money.
- Other co-conspirators and facilitators. Trafficking cases, almost by definition, are not solo operations. There are recruiters, transporters, advertisers, “bottom” operators, financial handlers, and the people who recruit customers. Each of them, in the right case, is a Chapter 98 and § 1595 defendant.
The first move in any well-built case is the defendant map. We build the map before we file, because the map tells us which defendants to name, in which order, and on which insurance tower each one sits. Naming the wrong defendant, in the wrong order, with the wrong theory, can leave the recovery short by millions. The map is the difference.
How We Build a Civil Trafficking Case From the Day You Call
A trafficking case is built in three races at the same time. We have to build the case against the perpetrators; we have to build the case against the commercial defendants; and we have to build the case for damages. We work all three from day one. The order below is the order in which the work actually happens.
Hour zero to hour 24 — preservation. This is the work that cannot wait. We send out preservation letters the same day we are hired. Every defendant is on notice: do not delete, do not overwrite, do not “lose,” and do not “misplace” the surveillance footage, the key-card logs, the folio and PMS records, the housekeeping logs, the reservation records, the incident reports, the point-of-sale records, the email and chat logs, the call-detail records, the body-worn-camera footage, the dispatch logs, the training records, the personnel files, the human-resources files, the marketing materials, the loyalty-program data, the app telemetry, the GPS pings, the electronic-discovery preservation notices, and the on-scene photographs. We do this because the evidence in trafficking cases is the most perishable of any case type we handle, and the defendants know it. The hotel that “cannot locate” its video, the platform that “cannot retrieve” its moderation queue, the employer that “no longer has” the personnel file — every one of those “cannot” answers is something we can defeat if we are on the record in time.
Days 1 to 30 — the formal civil investigation. We work the case alongside the criminal investigation in the way the law allows. We subpoena the police records, the 911 audio, the Computer-Aided Dispatch (CAD) logs, the prior call-for-service history at the address, the body-cam footage, the probable-cause affidavit, the indictment (once returned), and the discovery the State has produced. We pull the prior complaints to the same property, the prior code-violation history, the prior ownership and management history, and the prior litigation involving the same property or the same operators. We retain a trafficking-forensic expert to map the demand-side of the operation. We retain a medical-and-psychological expert to begin the life-care plan.
Days 30 to 90 — the formal civil complaint. We draft and file the petition. We name the right defendants, in the right order, in the right court. We plead Chapter 98, we plead § 1595, and we plead every related state-law theory the facts support — negligence, negligent hiring, negligent supervision, negligent entrustment, premises liability, negligent security, fraud, civil conspiracy, and any others the evidence requires.
Months 2 to 12 — discovery and damages. Discovery is where the case becomes real. We take depositions under oath of the front-desk staff, the housekeeping supervisors, the shift managers, the general manager, the brand-area director, the regional director, the trainer who did or did not train the staff, the platform’s content-moderation personnel, and the defendants themselves. We retain a forensic economist to build the life-care plan and the lost-earning-capacity model. We retain a treating-clinician team to document the injuries. We prepare the case for trial from day one, because the best settlements come from cases the defense believes we are willing to try.
Months 12 to 36 — resolution. Most well-built civil trafficking cases resolve before trial, but only because the defense sees the case the way the jury would. We do not settle for a number the case is not worth. The trial calendar is real, and we use it.
The Evidence That Disappears If You Wait
The single most important reason to call us in the first 24 hours is the evidence clock. The records that prove a trafficking case and the records that prove who is responsible for it begin to die the moment the case starts.
- Hotel surveillance video. There is no federal statute that requires a hotel to keep its surveillance footage for any specific period. Industry practice is a rolling overwrite, often on a 14-day, 21-day, or 30-day cycle. The footage that would show the trafficker walking through the lobby with a child, the cash payment at the desk, the room keys being handed over, the room being used by multiple men, and the front-desk staff’s failure to intervene — that footage is gone, legally, in a month. If a preservation letter is on file, the chain of duty is in place. If not, the footage is silently overwritten.
- Key-card access logs and property-management-system records. Key-card swipes, room-entry logs, electronic folio records, reservation and payment records, and housekeeping service logs are the documentary spine of any civil case against a hotel. The hotel’s own system shows who entered the room, how often, when, and on whose reservation. These records die on the property’s own retention schedule, which is often surprisingly short, and almost always shorter than the civil discovery clock.
- Police and 911 records. CAD logs, dispatch audio, 911 audio, body-worn-camera footage, and the incident reports from the on-scene officers are the official record. They are recoverable through public-records requests and through the criminal case, but they move fastest when requested early. Detective turnover, evidence-room backlogs, and media-cycle pressure all work against the family. We move on these records within 72 hours.
- The platform’s content-moderation data. The website that hosted the ad knows when the ad was posted, who posted it, who reported it, who saw it, who interacted with it, when it was taken down, and what content-moderation policies were in place at the time. That data is the federal-civil case against the platform under § 1595, and it is also the data the platform’s own terms of service and data-retention policy govern. We move to preserve it the same day.
- The mandatory training records. Texas law requires human-trafficking-awareness training for hotel employees, and the failure to comply is evidence of negligence per se. Whether the hotel had the records, whether the records are complete, whether the training was given in the way the law requires — all of this is documentary. We pull the training records, the curriculum, the completion logs, the audit reports, and the prior-incident reports.
- The financial records. Cash payments, prepaid card use, money-services-business flows, mobile-payment-app records, and the financial-paper trail that connects the trafficker to the venue and to the commercial defendants are the records that prove the “knowingly benefited” theory. These records live on bank servers, processor servers, and app servers, and they die on those servers’ retention schedules without a preservation demand.
- The victim’s own medical and treatment records. The medical record the hospital created at the moment the child was recovered is the foundation of the damages case. We preserve it, work with the treating team, and make sure the documentation captures the full scope of the harm.
The next 72 hours matter more than the next 72 weeks. The most expensive mistake a family can make in a trafficking case is waiting to see if the criminal case works out before talking to a civil lawyer. By the time the criminal case is over, the hotel cameras, the platform data, and the financial records may all be gone. We send the preservation letters on the day we are hired. We move at the speed the evidence requires.
The Online-Advertisement Layer — How the Website Becomes a Defendant
We want to spend a moment on this, because it is the part of the case most families do not understand. The ad with the missing child’s photograph next to an adult woman is not a sidebar. It is the central exhibit in a federal civil case. The website that hosted the ad knew, or should have known, that the ad was offering commercial sex involving a child. Under federal law, once that knowledge is established, the website is on the hook under § 1595 for knowingly benefiting from the venture. FOSTA removed the § 230 shield for this exact fact pattern. The website’s content-moderation policies, its reporting mechanisms, its actual knowledge from internal reports, its takedown timelines, and its payment-processing records are all evidence. We have seen these cases settle for eight figures, and we have seen them try the same cases for a number the jury did not believe.
The principle is simple: a website that took ad revenue from a posting that pictured a trafficked child is not a neutral platform for that posting. The First Amendment does not protect the platform from the consequence of its own commercial decision. The website has insurance for this exposure, it has a general counsel’s office for this exposure, and it has a settlement budget for this exposure. The civil case names that exposure, and it puts the platform’s records under oath.
Damages in a Texas Civil Trafficking Case
The damages side of a Chapter 98 case is built to a lifetime, not a moment. The defense will try to push the case toward the small, immediate numbers — the emergency-room bill, the immediate counseling bill, the temporary housing cost. We do not let the case shrink to that. The damages architecture we use in a trafficking case has six pillars, and the jury hears every one.
Past medical and psychological care. The child was taken to medical care at the moment of recovery. That is the first of what will be many rounds of treatment — emergency, pediatric, forensic, and then the long, specialized trauma treatment that follows. Emergency and acute care are recoverable as past medical. The forensic exam is recoverable. The intake evaluation, the initial trauma assessment, the medication management, the initial therapy, the residential placement, if any, and the diagnostic workup are all recoverable as past medical.
Future medical and psychological care. This is where the case becomes seven figures and eight figures. Trauma-focused cognitive-behavioral therapy, EMDR, somatic experiencing, attachment-based family therapy, substance-use treatment if needed, neuropsychological follow-up, psychopharmacology, psychiatric care, and the long-term residential and supportive services a child exploited for commercial sex will likely need across adolescence and into adulthood are all recoverable. We retain a life-care planner and a forensic economist to build the number, and we model the cost of care over the rest of the child’s expected life. The numbers in serious trafficking cases routinely run into the seven figures for future care alone.
Past and future lost earning capacity. A child exploited during the formative years of education carries the loss of earnings across a working life. The forensic economist builds the model from the work-life tables the Bureau of Labor Statistics publishes, adjusted for the child’s projected education, the projected occupation, the projected income, and the present-value discount rate. The defense will argue the child could have been a low earner. The model accounts for that, and the model is built under oath.
Pain and suffering and mental anguish — past and future. This is the largest non-economic category in a trafficking case, and Texas law is unusually clear that mental anguish damages are recoverable even without physical injury. The evidence we use to support this number is the treating-clinician testimony, the trauma-specialist testimony, the standardized diagnostic instruments, the school-record impact, the family testimony, and the careful documentation of how the child’s life has been altered.
Exemplary (punitive) damages. Texas Chapter 98 expressly allows exemplary damages, and the conduct that supports them is built into the statute. Trafficking is intentional, exploitative, and often profitable. The jury is asked to add a punishment number on top of the compensatory number. In our experience, this is the part of the case that drives settlements, because the defense knows what a Texas jury will do with a Chapter 98 case when the conduct is as serious as the conduct here.
Loss of enjoyment of life, loss of consortium, and related non-economic heads. Texas recognizes the loss of a normal childhood, the loss of the ability to trust, the loss of the capacity to form healthy relationships, and the related non-economic harms that do not fit neatly into one category. We plead these as separate heads where the evidence supports them.
The numbers vary with the facts. The dossier and our experience with comparable cases put the recovery range in a properly built Texas Chapter 98 case against deep-pocket commercial defendants at $750,000 to $10,000,000 or more, depending on the depth of the pockets involved. A case against the two arrested women alone, who likely have limited assets, will not produce a recovery in that range. A case that also names the hotel, the platform, and the commercial entities that benefited, with the right insurance coverage on each, is the case that produces the number that funds a lifetime of care.
The Defense Playbook — And How We Beat Every Move
We will tell you what the other side will do, because the playbook is well-known to the insurance-defense firms that handle trafficking cases on the commercial-defendant side, and because the only way to beat a playbook is to know it is coming.
Play one — the “no knowledge” defense. The hotel, the platform, the brand, and the property-management company will each say they had no idea trafficking was happening on their property or on their site. The standard response in the law is that “should have known” is enough. Constructive knowledge is established by the prior-incident record at the same property, by the prior complaints and code-violation history, by the failure to deliver the mandatory human-trafficking-awareness training the law requires, by the failure to staff and supervise the front desk, by the cash-payment pattern, by the short-stay pattern, by the multiple-visitor pattern, and by the housekeeping-refusal pattern. We depose the general manager under oath and walk the constructive-knowledge record in front of the jury. The “no knowledge” defense dies on the stand.
Play two — the “we are a platform, not a publisher” defense. The website will say it is a neutral platform immune from civil liability for user-posted content under 47 U.S.C. § 230. FOSTA’s carveout at 47 U.S.C. § 230(e)(5) reopens that immunity for civil claims under 18 U.S.C. § 1595 where the conduct alleged is sex trafficking under § 1591. The platform’s own content-moderation and reporting records are the proof of what the platform actually knew. The “platform not publisher” defense dies in the platform’s own internal documents.
Play three — the “but the criminal case is pending” delay. The defense will ask for a stay of the civil case pending the criminal case. In our experience, civil cases in this exact posture proceed in parallel with the criminal case under the right case-management order. The criminal case is the State’s, and the civil case is the family’s, and the two are not in conflict. We move the case past the stay motion and into discovery. Time is the defense’s friend, and we do not give it to them.
Play four — the “we just rented a room” defense. The hotel will say renting a room to a paying guest is ordinary commerce. Under Texas Chapter 98, providing a venue with goods or services the operator knew or reasonably should have known were intended to be used in the venture is direct liability. The room was the venue. The room was the meeting point. The hotel’s own records show what was happening in the room. The defense dies in the hotel’s own key-card data.
Play five — the “we are just the local franchise” defense. The brand will say the local owner is the responsible party and the brand is only a licensor. This is the franchisor liability fight, and the right answer under Texas law is the same answer as in the negligent-security hotel cases we already handle. We plead the brand’s actual control over training, brand standards, the reservation system, the loyalty program, the marketing, the property inspections, and the price controls. The brand’s control is its exposure.
Play six — the “this is a sympathy case, not a damages case” defense. The defense will try to keep the jury focused on the criminal case and away from the lifetime economic damages. We counter with the life-care plan, the forensic economist, the treating clinicians, and the standardized diagnostic instruments. Sympathy does not fund therapy. The life-care plan does.
Play seven — the settlement-numbers lowball. When the case moves toward settlement, the defense will offer a number that is a fraction of the case’s value, in exchange for confidentiality and a general release. We do not recommend accepting a lowball on a trafficking case. The 15-year statute of limitations gives us the time to do the case right. We prepare the case as if it will be tried, and we settle it for the number a jury would return.
The point of naming the playbook is not to frighten you. The point is to make clear that we have seen every one of these moves before, and we have a counter for each one. The defense wins when the family does not understand the playbook. The defense loses when we are ready.
Texas Statutes of Limitations — The Clock, in Plain English
The deadline to file a civil trafficking case in Texas is set by Texas Civil Practice and Remedies Code § 16.0045, and it is the most plaintiff-favorable deadline in the country. An action under Chapter 98 must be brought not later than the later of (1) 15 years after the cause of action accrues, or (2) 15 years after the victim reaches 18 years of age, if the victim was a minor at the time of the alleged offense. For a child recovered today, that is a runway well into the child’s late twenties. The deadline is not the problem. The problem is the evidence clock, which is much shorter than the legal deadline, and which is why we move in the first 24 to 72 hours.
For wrongful-death claims that may arise in the most serious trafficking cases, the Texas wrongful-death statute of limitations is two years from the date of death under § 16.003. For survival claims brought on behalf of the decedent’s estate, the same two-year clock applies. For ordinary personal-injury claims (which the case will also plead in the alternative), the Texas personal-injury statute of limitations is two years under § 16.003. None of these clocks affect the Chapter 98 case, which is the primary claim in a trafficking matter, and none of them should ever be the reason a family waits. The Chapter 98 case is the long clock, and the long clock is not the friend of the family — the short evidence clock is. We build the case in the evidence window, and the Chapter 98 deadline is the safety net under it.
The Texas Human Trafficking Prevention Task Force, the Training Mandate, and Negligence Per Se
Texas did not leave the hospitality industry to figure out the trafficking problem on its own. The Texas Human Trafficking Prevention Task Force, housed in the Office of the Governor, is the state’s coordinating body, and the legislature has imposed a mandatory human-trafficking-awareness training duty on hotel employees. That duty is enforceable. A hotel that did not deliver the training, that did not document the training, or that did not enforce the training in its actual operations is, in a civil case, a defendant that has built its own negligence per se argument for the plaintiff. We use the training records the same way we use any other compliance record — we depose the trainer, we depose the trainees, and we walk the jury through the gap between what the law required and what the property actually did. The gap is often the case.
Our Team — The Two Lawyers Who Will Carry This Case
Ralph Manginello is the managing partner of Attorney911 — The Manginello Law Firm, PLLC. He has been a Texas trial attorney since November 1998, more than 27 years, and is admitted to the U.S. District Court for the Southern District of Texas. Ralph built his practice the way a serious trial practice is built: by trying cases, by learning how the other side picks jurors, builds reserves, and frames damages, and by bringing the same standards to every file regardless of how big the insurance tower looks on the other side. Before law school, Ralph was a journalist, and that training shows in how he investigates a case — he finds the document that breaks the case open, and he does not stop until he finds it. He speaks Spanish. He is rated Excellent on Avvo with a 5.0 client-review score, and he is a member of the Texas Trial Lawyers Association, the Houston Bar Association, and the National Association of Criminal Defense Lawyers. He is the lawyer you want in the room when the defense starts talking about constructive knowledge, prior incidents, and the “should have known” standard. Read Ralph’s full bio here.
Lupe Peña is the firm’s associate attorney. Lupe is also a former insurance-defense attorney — a fact we lead with, not hide, because it is the reason he is dangerous on the other side of the table. Lupe spent years inside a national defense firm, in the rooms where adjusters and their software valued claims like your child’s and decided how much they were worth, and where defense counsel built the strategy to deny, delay, and devalue. He knows Colossus, he knows the IME doctor play, he knows surveillance, he knows the reserve-setting that goes on behind the closed door. He now uses that knowledge for the injured. He is fluent in Spanish, and he conducts full client consultations in Spanish without an interpreter, which matters in trafficking cases where the family may prefer to tell the story in their first language. He is a third-generation Texan with family roots to the King Ranch, born, raised, and living in Sugar Land. He has been a Texas attorney since December 2012. Read Lupe’s full bio here.
Together, Ralph and Lupe bring the outsider’s perspective of the plaintiff bar and the insider’s perspective of the defense bar to every case. That combination is rare, and in a trafficking case it is the difference between a case the family can win and a case the defense can wear down. Contact our team here. Hablamos Español.
Why the Page Is Here, And Why It Matters That You Are Reading It
A child in Montgomery County was recovered from a vehicle at a hotel on March 9, 2026, because investigators at the sheriff’s office and Texas DPS did their jobs, and because the system worked this time. The system does not always work. A great many trafficking cases in Texas and across the country are not interrupted, and a great many survivors never see the inside of a courtroom. The reason we wrote this page is that the survivors who do come forward, and the families who love them, deserve to know the law is on their side and that there is a team ready to enforce it. Texas Chapter 98 gives you a 15-year window. Texas’s mandatory training laws give you a negligence-per-se argument. Federal law under § 1595 and FOSTA gives you a federal civil case against the platform that hosted the ad. The evidence clock is short, but we move on day one.
The cases we handle are the cases we have built our practice around. Catastrophic-injury and trafficking cases are not dockets we dabble in. We handle commercial-truck collisions, refinery and industrial injuries, offshore and maritime injuries, construction injuries, toxic-tort cases, brain-injury and wrongful-death cases, and the cases that turn on a venue’s failure to keep a child or a guest safe. The full list of our practice areas is here. If you are a family in Conroe, in Montgomery County, on the I-45 corridor, in Houston, in Galveston, in Beaumont, or anywhere in Texas, and your family is in the situation this page describes, we want to talk to you. We will come to you. We will work around your child’s school schedule, your work schedule, and the demands of the criminal case. The consultation is free, the case costs you nothing unless we win, and we will tell you on the first call whether we are the right team for the case. If we are not, we will tell you who is. Past results depend on the facts of each case and do not guarantee future outcomes.
Call us right now. 1-888-ATTY-911. We are on the phone 24 hours a day, 7 days a week. Free consultation. No fee unless we win. Hablamos Español.
Frequently Asked Questions
My child was just recovered by police. Can we still file a civil trafficking lawsuit?
Yes. The criminal recovery does not affect the civil case. In fact, the criminal recovery is part of the civil case — the records of the recovery, the medical care the child received, the police investigation, and the evidence the State developed are all evidence in the Chapter 98 case. Texas gives a trafficking survivor a 15-year window under § 16.0045. The most important thing to do right now is preserve the evidence. Call us before you sign anything, talk to any insurance adjuster, or let any records be discarded. 1-888-ATTY-911.
How long do we have to file in Texas?
Under Texas Civil Practice and Remedies Code § 16.0045, an action under Chapter 98 must be brought not later than the later of 15 years after the cause of action accrues, or 15 years after the victim reaches 18 years of age if the victim was a minor at the time. For a child recovered today, the deadline is well into the child’s late twenties. The legal deadline is not the problem. The evidence clock is the problem. The hotel cameras, the platform’s content-moderation data, the financial records, and the witness memories all begin to die immediately. We build the case in the evidence window.
Can we sue the hotel where the meeting was supposed to take place?
Yes, in most cases. Under Texas Chapter 98 § 98.002, a person or business that knowingly benefits from participating in a trafficking venture, including by providing the venue with goods or services the operator knew or reasonably should have known were intended to be used in the venture, is directly liable. The hotel’s cameras, key-card logs, folio records, housekeeping logs, incident reports, and the mandatory human-trafficking-awareness training records the law requires are the spine of the case against the property. The hotel has a commercial general liability policy for this kind of exposure, and we make that policy part of the case.
Can we sue the website that advertised our child?
Yes. Under federal law, the Allow States and Victims to Fight Online Sex Trafficking Act of 2017 (FOSTA) carved back the broad immunity shield of 47 U.S.C. § 230 for civil claims under 18 U.S.C. § 1595 where the conduct alleged is a violation of 18 U.S.C. § 1591, the federal sex-trafficking-of-children statute. The website’s content-moderation records, takedown timelines, payment-processing records, and reporting mechanisms are evidence of what the platform actually knew. We have seen these cases settle for eight figures, and we have seen them tried. The civil case names the platform’s exposure, and the platform has the insurance and the budget for the exposure.
What damages can my child recover?
Under Texas Chapter 98, a trafficking survivor can recover actual damages including mental anguish damages even without physical injury, future medical and psychological care, past and future lost earning capacity, pain and suffering, loss of enjoyment of life, and exemplary (punitive) damages. There is no damages cap. Court costs and reasonable attorney’s fees are recoverable. The total recovery depends on the defendants named, the insurance available, the severity of the harm, and the strength of the evidence. The case-value range in a properly built civil case against deep-pocket commercial defendants is $750,000 to $10,000,000 or more, depending on the depth of the pockets involved.
Will filing a civil case interfere with the criminal case?
No. The criminal case and the civil case are separate, with different parties, different burdens of proof, and different remedies. We coordinate the civil case with the criminal case to avoid any interference, and the courts are experienced in managing parallel cases. In our experience, civil cases in this posture proceed under the right case-management order, and a stay is not the default. The defense will ask for a stay; we are prepared to argue against one.
What if my child does not want to face the trafficker in court?
We hear this question a great deal, and we want to be honest: most civil trafficking cases resolve before trial, and the survivor does not have to testify at trial in many resolved cases. Where a trial becomes necessary, our team is trained to prepare a child survivor to testify in a way that protects the child’s dignity and limits the trauma of the courtroom. There are also procedural protections — closed proceedings in some circumstances, the use of recorded statements, and the use of expert testimony to carry the burden of proof the child should not have to carry personally. We walk the family through every one of these options.
Is the consultation confidential? Will the trafficker know we are suing?
The consultation is confidential. The attorney-client privilege protects every word you say to us. The trafficker learns of the lawsuit only when we file the petition and serve the defendants. From that point, the case is a public record, but the public-record nature of a civil case is not a reason to delay, and it is not a reason to be afraid. In our experience, filing a civil case often empowers a survivor rather than retraumatizing them, because the case names the trafficker and the commercial defendants in a public forum and demands accountability in writing.
Can we get therapy and treatment paid for while the case proceeds?
We move quickly to put the child’s treatment on a foundation the case will support. In the right case, we can work with the defendant’s insurance carrier to fund treatment as part of the case. We can also work with victim-compensation funds and with the medical providers to ensure the child receives the care that is needed now, not after the case resolves. We connect families to the right trauma-specialty treatment team, and we work the documentation so the treatment records support the damages case.
How much does it cost to hire a trafficking lawyer?
We work on contingency. No fee unless we win. The free consultation is the only time you pay anything out of pocket, and that consultation is free whether or not you hire us. If we do not win, you owe us nothing for our time or our expenses. If we do win, our fee is a percentage of the recovery that we agree to in writing before we begin. Past results depend on the facts of each case and do not guarantee future outcomes.
What evidence do you need from us right now?
The first thing we need is the time and the space to send out the preservation letters the same day you call. After that, we need the child’s medical and treatment records, the police case number, the name of the investigating agency and the lead detective, the address of any property where the trafficking took place, the names of any witnesses including family members, the names of any businesses or websites involved, and the child’s school records. We will walk the family through every document request, and we will obtain most of what we need through subpoena and through the discovery process. We do not put the burden of evidence-gathering on the family.
Is the page only for families in Conroe?
No. The civil case is the same civil case in Conroe, in Houston, in Dallas, in San Antonio, in Austin, in El Paso, in the Rio Grande Valley, and in every Texas county. We handle trafficking civil cases from our Houston offices and across the state, and we will travel to the family. The Texas law applies statewide. The I-45 corridor, the I-10 corridor, and the I-35 corridor are all trafficking corridors, and we have seen cases from all of them.
If your family is in this situation, the next move is a phone call. 1-888-ATTY-911. Free consultation. No fee unless we win. We answer 24 hours a day, 7 days a week. Hablamos Español. Contact Attorney911 here. Past results depend on the facts of each case and do not guarantee future outcomes.