The Room at the Norcross Red Roof Inn: Why the Hotel, Not Just the Trafficker, Can Be Held to Account
If you are reading this in the middle of the night, you are probably not here for a primer. You are here because something happened to you or to someone you love at the Red Roof Inn on Brook Hollow Parkway in Norcross — and you are starting to ask the question that most survivors do not ask soon enough: the man who hurt me is one person, but the room he kept going back to, the front desk that kept handing him a key, the brand on the sign — do they answer for this too?
The short answer is: yes, federal law gives you that door. The longer answer is what this page is for. We are a Texas-based trial firm with a Georgia practice, and we handle exactly these cases — civil rights and premises liability suits against hotels, motels, and short-term-rentals for survivors of sex trafficking. Ralph Manginello has spent more than 27 years in courtrooms, including federal court; Lupe Peña is a former insurance-defense attorney who now works the inside of the system against it, and conducts full consultations in Spanish. The page that follows is what we tell our own family if they called us tonight.
We work on contingency — 33.33% before trial, 40% if it goes to trial. We don’t get paid unless we win your case. Your consultation is free, and you can call us 24 hours a day at 1-888-ATTY-911.
The Eleven-Second Moment: Why a Survivor May Feel It Was Too Late to Sue
The federal TVPRA civil remedy has a clock most survivors never hear about — and it works in their favor:
“No action may be maintained under subsection (a) unless it is commenced not later than the later of— (1) 10 years after the cause of action arose; or (2) 10 years after the victim reaches 18 years of age, if the victim was a minor at the time of the alleged offense.”
— 18 U.S.C. § 1595(c)
Ten years from the act — and if you were a child when it happened, ten years from your 18th birthday. A person trafficked as a 14-year-old can still file until she is 28. Many survivors who believe the door has shut find that the door is still open.
Georgia’s own statute of limitations for premises-liability personal-injury claims is two years under O.C.G.A. § 9-3-33, but the federal TVPRA claim runs on its own ten-year clock and is brought in federal court, not state. For trafficking claims that also sound in ordinary negligence and premises liability, we file the federal claim first to lock in the longer limitations period and then evaluate whether to add the state-law claims in the same complaint. Don’t let the calendar decide for you — call us and we will tell you what your specific clock looks like.
The Red-Flag Pattern Hotels Are Trained to See (and That This Case Alleges Was Ignored)
The list that follows is built from the kind of warning signs the industry itself has trained staff to recognize — and that the lawsuit alleges were ignored at this property. The federal case law treats these as evidence a jury can hear:
- Cash payments for rooms, sometimes multiple nights paid one day at a time
- No ID, or an ID that doesn’t match the person standing at the desk
- A third party renting a room for someone who never appears
- “Do not disturb” holds that run for days; housekeeping refusals
- Heavy short-stay foot traffic — many men to one room, in and out in 15 minutes
- Minimal luggage, or no luggage at all
- Excessive requests for towels, sheets, or other amenities consistent with a high-volume use
- A young woman or girl who seems anxious, controlled, or unfamiliar with the property
- Frequent turnover of female companions brought by the same male guest
- Prior law-enforcement contact with the property, complaints, or 911 hang-ups
The “should have known” standard does not require a confession. It requires the jury to see what a careful operator in the hotel’s position would have seen. When the same desk clerk checked in the same man forty times over three months and saw forty different young women rotate through his room, the statute is satisfied.
The Insurance-Adjuster Playbook (and How We Beat It)
Hotel liability and trafficking claims are usually tendered to the hotel’s commercial general liability carrier — but many CGL policies contain assault-and-battery exclusions and increasingly specific human-trafficking exclusions. The defense’s first moves are predictable. Here is what they will try, and how we answer each one.
Play 1: “The conduct was an intentional act outside the scope of coverage.” The insurer argues the trafficking was an intentional tort by the trafficker, not an accident, and that the policy’s assault-and-battery exclusion bars coverage. The counter: we are not suing the trafficker under the CGL — we are suing the hotel for its own conduct (negligent hiring, negligent security, failure to warn, negligent training). The hotel’s own negligence is the loss, and the exclusion does not reach negligent acts of the insured.
Play 2: “We were never put on notice.” The insurer argues no one told the hotel until the lawsuit arrived, so the hotel cannot be on the hook for failing to act. The counter: prior police calls, the same staff seeing the same man for months, internal incident logs, the brand’s own safety training materials — and the moment the survivor or our office gave notice, the hotel had a duty to preserve evidence. The “we never knew” line collides with the duty to have known.
Play 3: “The survivor was a willing participant, not a victim.” This is the cruelest, oldest defense in trafficking cases. The counter is the law itself: a person forced, coerced, or fraudulently induced into commercial sex is a victim under 18 U.S.C. § 1591, regardless of any appearance of consent. We work with trauma-informed experts and the survivor’s own medical and psychological record to dismantle this argument before it ever reaches a jury.
Play 4: “The brand didn’t run the property.” The franchisor points at the franchisee; the franchisee points at the franchisor. The counter: name the operating company, name the parent, name the management company, name the insurance tower behind each, and let the discovery and the depositions sort out who actually made the decisions. Doe v. Red Roof Inns is a real defense to a franchisor-only theory — but it does not protect the operator, the manager, or the company whose name was on the front desk.
Play 5: “We’ll settle for nuisance value.” The early offer. The counter: we know the value of the case because we have a life-care plan, an economist, and a treating clinician — and we have a record of taking these cases to verdict. The “lowball” is itself evidence at trial.
Who We Are, and Why This Is Our Fight
This is not a niche we wandered into. Ralph P. Manginello has been a trial lawyer for more than 27 years, admitted in Texas in 1998 and admitted in federal court in the Southern District of Texas. He is a member of the Texas Trial Lawyers Association, the Houston Bar Association, and the National Association of Criminal Defense Lawyers. Before law school he was a journalist; the instinct to find the document everyone else missed has never left him. He and his wife Kelly live in Houston with their children RJ, Maverick, and Mia.
Lupe Peña is a third-generation Texan, admitted in Texas in 2012 and in federal court in the Southern District of Texas. He was a former insurance-defense attorney at a national defense firm — he knows how the other side values a case, how Colossus and similar software price injuries, how the IME doctor gets picked, and where the adjuster’s delay tactic lives. He uses that knowledge for the injured now, and he is fully bilingual — conducting entire client consultations in Spanish without an interpreter. A native of Sugar Land with family roots to the King Ranch, Lupe is the advantage most firms don’t tell you about: the inside of the system, working for you.
We work these cases with local Georgia co-counsel where required, and we do it on contingency. There is no fee unless we win. The consultation is free. We are available 24 hours a day, every day, at 1-888-ATTY-911.
Frequently Asked Questions
Can I sue the Red Roof Inn on Brook Hollow Parkway for what happened to me there?
Yes. Under 18 U.S.C. § 1595(a) you can sue any business that knowingly benefited from a venture it knew or should have known was engaged in trafficking. Under Georgia law, you can also pursue a premises-liability claim under O.C.G.A. § 51-3-1 and a Georgia RICO claim under O.C.G.A. § 16-14-1 et seq. against the property operator. The right defendants, the right court, and the right theory depend on the specific facts — call us to find out where your case fits.
How long do I have to file a sex-trafficking lawsuit in Georgia?
For the federal TVPRA claim, ten years from the act, or ten years from your 18th birthday if you were a minor — see 18 U.S.C. § 1595(c). For Georgia common-law premises-liability claims, the statute of limitations is generally two years under O.C.G.A. § 9-3-33. We file the federal claim first to lock in the longer period and then evaluate state-law claims on the same facts.
Do I have to prove the hotel’s management knew about the trafficking?
No — not actual knowledge. You have to prove the hotel knew or should have known, which is a constructive-knowledge standard. If a reasonable operator in the hotel’s position would have recognized the warning signs (cash payments, no-ID guests, the same room with a stream of different men, housekeeping refusals, prior police calls), the constructive-knowledge element is satisfied — even if no one at the front desk was formally trained to flag it.
What about the Red Roof brand on the sign — can I sue the franchisor, not just the local owner?
It is harder, and we will not pretend otherwise. The Eleventh Circuit’s Doe #1 v. Red Roof Inns, Inc., 21 F.4th 714 (11th Cir. 2021), dismissed franchisor defendants because renting rooms and observing trafficking is not enough to make the brand a participant in the venture. But the same court, in A.G. v. Northbrook Industries, Inc. (March 30, 2026), vacated summary judgment for an operator and made clear that active support or facilitation of the operation is enough. We plead the operator, the manager, and the parent — and we build the franchisor case on operational control and direct benefit, which is the path the surviving cases have taken.
What evidence is most important in a hotel trafficking case?
The hotel’s own records. The hotel’s CCTV and key-card logs, the property management system, the housekeeping refusal notes, the police CAD history for that address, and the brand’s own safety training materials. These are the documents that prove what the hotel knew and when it knew it. They die in days to weeks if no one demands preservation — which is why we send the letter the week you call.
Will my case be confidential? I’m afraid of being identified.
Georgia civil cases are generally public, but the court can enter protective orders sealing sensitive information, and we will move for that where appropriate. Your name and identifying details are not published without your consent. We work with trauma-informed providers on every step of the case.
What about damages for what I went through — the PTSD, the therapy, the lost years?
Yes. Economic damages (medical, therapy, lost earning capacity) and non-economic damages (pain and suffering, emotional distress, loss of enjoyment of life) are both recoverable, and so are punitive damages where the evidence supports a finding of conscious indifference under O.C.G.A. § 51-12-5.1. Federal law also authorizes recovery of reasonable attorneys’ fees.
Is there any way to get compensation for an entire pattern of victims, not just me?
Potentially. Federal Rule of Civil Procedure 23 and Georgia state-class procedure can support a class action where the facts are common. The right vehicle depends on the size and uniformity of the pattern, and on the court’s view of the case. We can evaluate that on intake.
What does it cost me to hire your firm?
Nothing up front. We work on contingency — 33.33% before trial, 40% if we go to trial. We are not paid unless we win. The consultation is free, and the call is 24/7 at 1-888-ATTY-911.
Will the hotel’s insurance company pay, or will the hotel pay out of pocket?
The hotel’s commercial general liability tower is the first target. CGL policies often contain assault-and-battery or trafficking exclusions, which is why we file the case as a negligence claim against the hotel — the hotel’s own failure to act, not the trafficker’s act — to keep the insurance on the table. Beyond insurance, the hotel company itself, the parent brand, and any management company are separate pockets, and we pursue each one separately.
I am not in Georgia — can you still help me?
Yes. We are a Texas-based trial firm with a Georgia practice. We handle federal TVPRA cases nationwide and work with local co-counsel where required. The case filed in the Norcross matter was filed in Gwinnett County Superior Court, but the federal TVPRA case can be filed in the federal district that covers the trafficking venue. Call us at 1-888-ATTY-911 and we will tell you what we can do.
I am undocumented. Will that affect my case?
No. The TVPRA was written specifically to protect trafficking survivors, regardless of immigration status, and we do not share client information with immigration authorities. Your status is not relevant to the civil claim, and we will not let it become a barrier to your recovery.
How to Reach Us — and What Happens When You Do
The call is free. The consultation is confidential. We do not sign you up for anything on the first call — we listen, we answer your questions, and we tell you honestly whether we are the right firm for your case. If we are not, we will tell you who is. If we are, we move fast.
“Past results depend on the facts of each case and do not guarantee future outcomes.”
If you or someone you love has been trafficked at the Norcross Red Roof Inn, at another budget motel in Gwinnett County, or at any hotel anywhere in this country, call us at 1-888-ATTY-911 — twenty-four hours a day, seven days a week. We are here, we are ready, and the statute gives you ten years. Don’t let the clock, or the hotel’s camera loop, or the silence of the past, decide this for you. Contact Attorney911 now.
Hablamos Español. Lupe Peña runs full consultations in Spanish, and we have bilingual staff — because this case, and every case like it, deserves to be heard in the language the survivor actually prays in. If you are more comfortable in Spanish, ask for Lupe. If you prefer to read about your rights in the context of a car or truck crash, a brain injury, or a wrongful death, we handle those too — Ralph has spent 27 years in courtrooms, including federal court, and Lupe has spent years on the inside of the insurance-defense system he now works against. Meet Ralph here. Learn more about our practice areas and our contingency fee structure.
We don’t get paid unless we win. The consultation is free. 1-888-ATTY-911. The first move we make is to preserve the proof.