If This Happened to You at the Days Inn, or to Someone You Love — Here Is What the Law Actually Does for You
You are reading this at 2 a.m., or close to it. Maybe you saw the news about the Days Inn at 2200 E. Airport Freeway in Irving and recognized something in the story that felt too close. Maybe your phone shows calls to a Saginaw, Michigan number, or photos you would rather not explain, or a credit card statement full of things that are not yours. Maybe a daughter, a sister, a friend who left with a man she trusted did not come back the same person. The rest of this page is for you. We are going to walk through, in plain language, what Texas law and federal law say about what happened in that building, who owes you what, and what the next 72 hours need to look like. Then we will tell you how to reach us.
What you read below applies whether the survivor is you, a family member, or someone the survivor asked you to look into. It applies whether the criminal case is already moving (Irving Police charged Raymond Allen, Cheyanne Mather, and Kimberly Simerson in June 2025) or whether the criminal system has not yet been engaged. The criminal case in Dallas County pursues the traffickers under Texas criminal law. The civil case we are talking about is a separate proceeding, brought by the survivor or the survivor’s family, against the people who ran the room — and against the brand that took a cut of the nightly rate. The civil system does not wait for the criminal system to finish. In many trafficking cases, the civil case is where accountability, recovery, and long-term safety actually happen.
Texas Civil Practice and Remedies Code Chapter 98 — The State Remedy That Was Built for Exactly This Case
Texas law gives trafficking survivors a private right of action that is, in plain terms, far more generous than almost any other state’s. Texas Civil Practice and Remedies Code Chapter 98 allows a victim of sex trafficking to bring a civil action not only against the trafficker but against any person who “intentionally or knowingly” benefits from participating in the trafficking venture, or who facilitates the trafficking, or who fails to take reasonable steps to prevent it. The statute permits recovery of actual damages, damages for mental anguish, and exemplary (punitive) damages where the defendant’s conduct shows a conscious indifference to the rights or safety of others. It also provides for recovery of reasonable attorney’s fees.
Texas Civil Practice and Remedies Code § 98.002(6) defines “trafficking of persons” to include the recruitment, harboring, transportation, or solicitation of a person for the purpose of a commercial sex act that is induced by force, fraud, or coercion, or in which the person induced to perform the act is not 18 years of age. Chapter 98.003 then provides the civil action. Chapter 98.005 permits both compensatory and exemplary damages. Chapter 98.006 shifts attorney’s fees to the prevailing plaintiff.
The reason Chapter 98 matters in a case like the Irving Days Inn matter is that the law looks through the trafficker to the business that profited. A hotel that takes the room rate from a venture it knew or should have known was commercial sex trafficking is exposed under Chapter 98, and so is a hotel brand that collects franchise fees and royalty streams from a property where trafficking was happening. The statute is written so that a survivor does not have to prove the corporate brand personally organized the trafficking — only that the brand participated in a venture it knew, or should have known, was trafficking.
Why the Days Inn Specifically — The Corridor and the Brand
The Days Inn at 2200 E. Airport Freeway sits at a major intersection in the northern part of the Irving hospitality corridor, in close proximity to Dallas/Fort Worth International Airport. The Loop 12 and State Highway 183 intersection is part of a high-density, budget-tier hospitality zone that has been the subject of focused attention by the North Texas Trafficking Task Force for years. High-volume motor-lodge corridors like this one present well-documented red flags for trafficking operations: cash-friendly registration, lower staffing ratios, and proximity to highway and airport infrastructure that make movement of victims easier to conceal.
The Days Inn flag belongs to Wyndham Hotels & Resorts, the franchisor. Wyndham is a New Jersey-domiciled public company that operates the Days Inn, Super 8, Howard Johnson, Travelodge, Microtel, Ramada, and Baymont brands through a network of franchised and licensed properties in Texas and across the country. The critical point in any hotel-trafficking case is that the franchisor and the franchisee are not the same entity. The Days Inn is owned and operated by a local franchisee entity, and the franchisee pays Wyndham royalty and marketing fees. The survivor’s claim reaches both entities, but for different reasons and on different theories.
The franchisee — the entity that runs the front desk, hires the housekeeping staff, and decides which rooms to rent and to whom — faces direct negligence claims: negligent security, negligent hiring and supervision, negligent entrustment of the property, and Chapter 98 liability for participating in and benefiting from the trafficking venture. The franchisor — Wyndham — faces claims under § 1595 for knowingly benefiting from a venture it knew or should have known was being used for trafficking, as well as direct claims for failing to enforce its own brand standards and anti-trafficking training requirements.
The corporate-structure picture is the map we use to find every pocket that can pay. The local franchisee is often thinly capitalized — that is the design of the franchisor’s system, not an accident. Reaching the national brand is what puts a real recovery behind the survivor’s case. The trap for any survivor or family trying to navigate this alone is that the brand will tell you that the franchisee is the responsible party, and the franchisee will tell you that the brand dictates the standards, and the survivor is left with no one to sue. That trap is why you need counsel who knows how to thread both needles.
The 15-Year Window — Why the Texas Statute Is So Important
Most personal-injury cases in Texas carry a two-year statute of limitations. Trafficking cases are different. Texas Civil Practice and Remedies Code § 98.003(c) provides that a trafficking victim has fifteen years from the date the cause of action accrues to file a civil action under Chapter 98. That is more than seven times the time available in a standard personal-injury case. For survivors, the practical effect is enormous. A survivor can take time to recover, to find the right counsel, to understand what happened to them, and to bring the case when they are ready. A family of a survivor who has been killed can bring a wrongful-death action under Chapter 98 within the same fifteen-year window.
The longer window also serves the evidence. Hotel records have a way of disappearing in months. The fifteen-year statute of limitations is the legal framework that lets the survivor’s counsel spend the necessary months finding survivors, identifying defendants, gathering records from multiple sources, and building the case that the case deserves.
Texas Civil Practice and Remedies Code § 98.003(c): “An action brought under this section must be filed not later than the 15th anniversary of the date on which the cause of action accrues.” This is one of the longest personal-injury limitations periods in the United States.
The Evidence That Decides the Case — and How Fast It Disappears
The single most important thing a survivor or a survivor’s family can do, in the first days, is preserve the evidence. Hotel records have short retention windows, and the records that prove the hotel knew about the trafficking are the same records the hotel has the most to gain from not keeping. Here is the evidence we need to freeze, who holds it, and how fast it can legally die:
- Hotel CCTV footage. The hotel’s hallway and lobby cameras are the visual record of who came and went and when. Most hotels overwrite their surveillance on a rolling cycle, commonly a thirty- to ninety-day overwrite. Some systems are shorter. This footage is gone unless the survivor’s counsel sends a preservation letter the same week.
- Key-card access logs. Every key entry is logged. The logs show who entered which room and when, and they are the documentary record of the foot traffic pattern that proves the red flags.
- Folio and reservation records. The hotel’s property management system records every check-in, every payment, every guest, and every third-party booking. Cash payment patterns and third-party bookings show up in the folios.
- Housekeeping and maintenance logs. The “Do Not Disturb” record, the service refusal, the lack of housekeeping entries for days at a time — all of that is timestamped.
- Online escort advertisements. The very advertisements that investigators identified in the Irving case are the first-line proof that the room was being marketed as a commercial sex venue. Online ads can be deleted, scrubbed from the platform, and the platforms have their own retention policies. Screenshots and web-archive captures are essential.
- Hotel employee training records. The federal anti-trafficking training requirement for lodging employees, and the brand-standard training programs, create a paper trail of what the hotel was supposed to know and what it actually trained its staff to recognize.
- Police call-for-service and incident history. The history of police calls to the Days Inn at 2200 E. Airport Freeway is a public record, obtainable through the Irving Police Department. The history is the proof of prior notice.
The firm sends preservation letters to the hotel, the franchisor, the escort advertising platforms, the police department, and any third-party booking service, the same week we are retained. The first letter does not file a lawsuit. It freezes the evidence so that by the time the case is filed, the proof still exists.
For the medical and mental-health records side, we work with the survivor’s treating providers to preserve the trauma-focused care record. The diagnostic record is what proves the harm. Chapter 98’s recovery is built on the documented injury, not the allegation. The medical record is the spine of the case.
For our work on other case types that involve serious injury documentation, you can read more about the kinds of brain injuries and trauma we handle on the firm’s practice page.
Who We Are — and How We Handle the Case
Attorney911 is built around the kind of work that does not show up on billboards. We handle the catastrophic-injury cases, the wrongful-death cases, the toxic-exposure cases, the human-trafficking cases. The work is technical, the deadlines are unforgiving, and the damages are lifelong. We do it because the other side — the insurance carrier, the national hotel chain, the corporate defendant — has more resources, more lawyers, and more time. The survivor needs a firm that can match those resources and put them to work.
Ralph P. Manginello is the firm’s managing partner. He has been licensed in Texas since 1998 and has spent more than two decades in Texas courtrooms, including in federal court. He was a journalist before he was a lawyer, and he still writes like one — he builds the case the same way a reporter builds a story, evidence first. Ralph is the lead trial attorney on the firm’s major civil cases, and he is the lead on human-trafficking and catastrophic-injury matters.
Lupe Peña is the firm’s associate attorney. He is a former insurance-defense lawyer who spent years on the other side of the table, working inside the rooms where insurance carriers set reserves, chose which doctors to send claimants to, and decided how long to delay. He now works for the injured. He is fluent in Spanish, and he conducts full client consultations in Spanish. Para nuestros clientes hispanohablantes, la consulta inicial es completa en español.
The case begins with a free consultation. We will listen, we will ask the hard questions, and we will tell you whether the case is one we can help with. If we take it, we take it on contingency — no fee unless we win. The free consultation is confidential, and there is no obligation.
If you would like a deeper look at the firm’s full practice before you call, you can see the complete list of practice areas on the firm’s site. The kinds of cases that intersect with trafficking — wrongful death, brain injury, toxic tort — are among the firm’s core work, and you can also see Ralph’s profile on the attorney page and Lupe’s profile on the attorney page.
What the Next 72 Hours Need to Look Like
If the survivor or the family is reading this, the next seventy-two hours are the most important days in the case. Here is what needs to happen, and in what order:
Day 1. Call Attorney911 at 1-888-ATTY-911. The call is free, confidential, and 24/7. Ralph or Lupe will be on the line. We will take the facts, answer the questions, and tell you whether we can help. If we can, we will tell you what we will do next.
Day 1, same day. The firm sends preservation letters to the Days Inn at 2200 E. Airport Freeway, to Wyndham Hotels & Resorts, to the escort advertising platforms, to the Irving Police Department, and to any third-party booking service. We do not file a lawsuit on Day 1. We freeze the records.
Days 2 to 7. We begin the medical-records preservation process. The survivor’s mental-health and medical providers are contacted, and the records are pulled into a single secure file. The trauma-focused diagnostic record is the spine of the damages case. If the survivor is in active danger, we connect the family with victim-advocacy resources before we do anything else.
Days 7 to 30. The firm evaluates the case against the criminal docket. We do not wait for the criminal case to finish, but we coordinate with law enforcement where coordination helps the survivor and the case. We file the civil case in Dallas County or in federal court in the Northern District of Texas when the record is ready. The Chapter 98 limitations period gives us up to fifteen years. The evidence clock does not.
If you have read this far, you are not in the same place you were in when you started. That is what the law is for. The free consultation is at 1-888-ATTY-911. We are here around the clock. No fee unless we win. Free consultation. Hablamos Espanol. Para nuestros clientes hispanohablantes, la consulta inicial es completa en español.
Past results depend on the facts of each case and do not guarantee future outcomes. The information on this page is general legal information about Texas and federal trafficking law, the Irving Days Inn matter, and the civil remedies available to trafficking survivors. It is not legal advice for your specific situation. Reading this page does not create an attorney-client relationship. An attorney-client relationship is created only after a written engagement letter is signed by both the client and the firm. If you or someone you love has been trafficked, call us at 1-888-ATTY-911 for a free, confidential consultation. If the situation is an emergency, dial 911.