If This Is What You’re Going Through, Read This First
You were trafficked out of a room at a Rodeway Inn on West State Road 84 in Dania Beach. Maybe it happened over weeks. Maybe it stretched into a year. Maybe someone you love was the one in that room, and you only found out after the fact — when the credit cards stopped making sense, or the texts stopped coming, or the police knocked on a door you never expected them to knock on.
Whatever brought you to this page, here is what you need to know right now: you are not to blame. The decisions that put you in that room were made by the trafficker. The decisions that kept the front desk handing over keys — week after week, cash by the hour, no ID, no questions — those were made by the hotel. The hotel took money from a setup that was happening in its building. The law in this country says that is not okay, and the law gives you a real path to hold every company in that chain responsible.
We work these cases. We know how the hotels are structured, how the records get preserved (or don’t), how the insurance carrier will try to settle you for a fraction of what your case is worth, and how the brand on the sign tries to point at the franchisee to avoid the bill. We have handled cases where the corporate structure was built specifically to keep survivors from collecting a dime, and we have found the seams. This page is written to show you what your rights are, what the fight will look like, and how to get help.
A free consultation is where we start. 1-888-ATTY-911 (1-888-288-9911).
The Allegations Against the Rodeway Inn in Dania Beach
The federal lawsuit filed in the Southern District of Florida names three defendants tied to a single property on West State Road 84 in Dania Beach, Broward County — a stretch of highway that runs from the Fort Lauderdale-Hollywood International Airport to I-95 and I-595, the corridor that moves cruise traffic in and out of Port Everglades, the place where the highway meets the harbor and the airport and a city of motels. The complaint alleges that a woman identified by the initials S.W. was sex-trafficked from this Rodeway Inn between 2019 and 2020, and that the three named defendants — Tropical Paradise Resorts (the property owner), EZ Hospitality (the management company), and Choice Hotels International (the franchisor) — failed to prevent the trafficking and profited from it while it was happening.
The complaint’s own language, quoted from the federal filing, is blunt: the defendants failed “to prevent and/or take steps to prevent this horrific criminal conduct from occurring at their hotel, so that [the defendants] could continue earning a profit at the expense of human life, human rights, and human dignity.”
Those are not abstract accusations. They describe a real pattern that has been pleaded in federal courtrooms around the country for years: a branded budget motel with a heavy cash-by-the-hour trade, a parade of men to a single room, a young woman who never appears at the front desk, housekeeping turned away, and a franchise brand collecting royalties every step of the way.
Why the Federal Trafficking Law Reaches Hotels
The case is built on a single federal statute: the Trafficking Victims Protection Reauthorization Act, specifically its civil-remedy provision at 18 U.S.C. § 1595(a). The text, taken directly from the U.S. Code, is shorter and more powerful than most people expect:
“An individual who is a victim of a violation of this chapter may bring a civil action against the perpetrator (or whoever knowingly benefits, or attempts or conspires to benefit, 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) in an appropriate district court of the United States and may recover damages and reasonable attorneys fees.”
— 18 U.S.C. § 1595(a) (Cornell LII verified)
What that text means in plain English is this: you do not have to prove the hotel did the trafficking. You have to prove the hotel took money from an operation it knew — or should have known — was trafficking people. That is a far lower bar than proving the front desk was part of the criminal conspiracy, and it is the reason this statute has opened the door to cases against hotels that previously thought they were untouchable.
The same statute also gives a survivor a long clock to file. 18 U.S.C. § 1595(c) sets a ten-year statute of limitations, and if the survivor was a minor at the time, the ten years does not even begin to run until her eighteenth birthday. For a person trafficked at sixteen, the federal filing window can run into her late twenties. The law was written to match what trafficking research actually shows — that survivors often take years to identify what happened to them, to escape, to stabilize, and to come forward.
The Four Elements the Hotel Has to Answer For
A § 1595 case against a hotel rests on four specific elements. Federal courts have been working through exactly what those elements require, and the case law has tightened considerably over the last few years. The four elements a survivor’s lawyer has to plead and prove are these:
- The defendant knowingly benefited — the hotel took money from the venture.
- The defendant participated in a venture — meaning the defendant took part in a common undertaking involving risk and potential profit. This is the hardest element, and it is the one the brand on the sign fights hardest.
- The venture violated the TVPRA as to this survivor.
- The defendant had actual or constructive knowledge of the violation.
The single most important appellate ruling in this space for a franchisor defendant is Doe #1 v. Red Roof Inns, Inc., 21 F.4th 714 (11th Cir. 2021). That case is a defense win — the Eleventh Circuit affirmed the dismissal of the franchisor defendants because the plaintiffs did not plausibly allege that the franchisors took part in the common undertaking. The lesson for a survivor is not discouraging. It is instructive: bare franchise fees, brand standards in a manual, and constructive knowledge that trafficking happens at motels in general are not enough. To reach Choice Hotels, the franchisor on the Rodeway Inn sign, the case has to plead concrete operational control and direct benefit from the trafficking rooms — not a passive franchise relationship.
That is exactly the line the case against Choice has to clear, and it is the line the survivors’ lawyers in this case are building around. The same year, a different federal court — the Southern District of Ohio in M.A. v. Wyndham Hotels & Resorts, 2025 WL 2696500 (S.D. Ohio Sept. 22, 2025) — denied summary judgment for franchisee hotel operator defendants, holding that renting hotel rooms could satisfy both the “knowing benefit” and “participation in a venture” elements, and that constructive knowledge (“should have known”) was enough. The law is split. The right answer depends on what the evidence shows about how this specific Rodeway Inn actually ran.
The Eleventh Circuit’s more recent A.G. v. Northbrook Industries decision, issued March 30, 2026, draws the line more precisely: ordinary room rental alone is not enough, but “active support or facilitation of the trafficking operation” — staff interactions with traffickers, allowing unverified room access, and ignoring trafficking indicators — can satisfy the participation element and let a jury decide. The legal question is not whether the case can be filed. It is whether the evidence shows a hotel that knew and participated, or one that lawyers will try to paint as merely the venue.
The “Should Have Known” Standard and the Red Flags the Hotel Is Trained to Spot
The hardest part of a hotel trafficking case is rarely the harm. The hardest part is the knowledge element — proving the hotel either knew or should have known what was happening. The good news is that the hospitality industry has, for years, trained its own staff to recognize trafficking indicators. Federal law, Florida law, and the major brand-standard manuals all converge on the same list. When a hotel’s front desk ignored those indicators, “we didn’t know” stops being a defense and starts being an admission.
The classic trafficking indicators in a motel setting are well established in DOJ and anti-trafficking training material, and they are the same indicators Florida law now requires staff to be trained on under Florida Statutes § 509.096 (the state’s mandatory anti-trafficking training requirement for lodging employees). The pattern at a property where trafficking is happening typically includes one or more of the following:
- Cash payment for rooms, especially when the hotel accepts cards elsewhere and a single guest insists on cash.
- Frequent refusal of housekeeping — the guest hangs a “do not disturb” sign for days at a time, and the hotel honors it.
- Excessive foot traffic to a single room, particularly a parade of different men at unusual hours.
- Minimal luggage — the occupant appears to live at the property but brings almost nothing with her.
- A third party rents and pays for the room while the occupant never appears at the front desk.
- Requests for rooms near exits — traffickers stage quick extractions.
- Visible fear or control — the occupant does not speak, looks to the trafficker before answering, cannot produce ID, or shows signs of injury.
- Trash and debris consistent with commercial sexual activity — used condoms, lubricant, packaging.
- Prior police calls to the property for similar concerns.
- A front desk that recognizes the trafficker by name and waves him through.
The presence of even a handful of these indicators at a Rodeway Inn over weeks or months is, in a court of law, constructive knowledge. Florida’s training requirement, federal case law on what a hotel “should have known,” and the very existence of brand-standard manuals that train staff to spot these signals all point the same way. When a hotel collects the cash and ignores the pattern, it is not a passive bystander. It is a business that made a business decision to keep collecting.
“An individual who is a victim of a violation of this chapter may bring a civil action against the perpetrator (or whoever knowingly benefits, or attempts or conspires to benefit, 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)…”
— 18 U.S.C. § 1595(a)
Florida Law Adds Another Avenue and a Separate Standard
The federal TVPRA is not the only tool. Florida has its own civil remedy for human trafficking codified at Florida Statutes § 772.104, which allows a victim of human trafficking to bring a civil action for damages. Florida also mandates, under Florida Statutes § 509.096, that lodging employees receive annual training to recognize and report human trafficking, and failure to comply creates a strong presumption of negligence under Florida law.
Florida’s modified comparative negligence standard is part of the framework. A survivor’s recovery is reduced by her own share of fault, and recovery is barred entirely if her share reaches the bar the state has set. In a trafficking case, the defense will try to use comparative fault to argue that the survivor “should have known better” or “should have left.” The case law is clear that this argument is not available to a trafficker or to a business that facilitated the trafficking — the law does not let the wrongdoer profit from blaming the victim. We will brief that argument in full and we expect to win it.
The Florida framework and the federal TVPRA work together. They are not in conflict. They are two doors into the same building. We open both.
The Corporate Shell Game and How We Pierce It
A Rodeway Inn sign is the last thing the franchisor wants to be associated with when a trafficking case hits the news, but it is the first thing the survivor sees when she walks in. The corporate structure is built specifically to create distance between the brand and the building. Three different entities may have profited from the same room:
- Tropical Paradise Resorts — the property owner. The name on the deed. Often a single-asset LLC built to hold this one building and nothing else.
- EZ Hospitality — the management company. The entity that hires the front-desk staff, sets the daily routine, decides when rooms get cleaned and when they don’t, and pays the bills.
- Choice Hotels International — the franchisor. The entity that licenses the Rodeway Inn flag, collects a percentage of room revenue, requires the property to meet brand standards, and benefits from every night the room is occupied, no matter who is paying or what is happening inside it.
In a federal trafficking case, the survivor’s lawyer names all three. The owner and operator are the natural targets — they are the people on the ground, the ones with direct control over how the property runs. The franchisor is the harder reach, and the Eleventh Circuit’s Red Roof decision (discussed above) sets the standard. To reach Choice, we have to show that the brand’s relationship with this specific property was not just a name on a sign. We have to show operational entanglement, revenue from the trafficking rooms, brand-imposed systems that controlled how the property actually ran, and ignored red flags that the brand’s own training materials say staff are supposed to act on.
In the Rodeway Inn case filed in the Southern District of Florida, the pleading has to do exactly that work. And there is a real, contemporaneous benchmark: in July 2025, a federal jury in the Northern District of Georgia — a different case, a different defendant, a different plaintiff, but the same kind of motel and the same kind of pattern — returned a $40 million verdict ($10 million compensatory, $30 million punitive) against a motel operator found to have participated in the trafficking venture. That verdict has not yet reached a final, unappealable judgment, and we will not present it as a guarantee, but it is a real jury’s real answer to the question of what this kind of conduct is worth when a case is properly tried.
The Defense Playbook: What the Hotel and Its Insurer Will Do
Insurance carriers defending hotels in trafficking cases run a recognizable playbook. We have seen the moves because Lupe Peña, who leads this work with us, spent years on the other side of the table as an insurance defense attorney at a national defense firm. He knows these plays from the inside. He knows the software, the reserve-setting, the IME-doctor shortlist, the surveillance timeline, and the policy-limits shell game — and he now uses that knowledge for survivors. Here is the playbook and how we counter each move.
Play 1: The franchisor points at the franchisee. “We don’t own or operate this Rodeway Inn. Tropical Paradise Resorts owns it. EZ Hospitality manages it. We just license a name and collect a fee.” This is the Red Roof play. Counter: we plead around it. The case is brought against all three defendants in the alternative, with a fully developed record on Choice’s actual operational control over the property — the reservation system, the brand standards manual, the training requirements, the royalty structure, the data and marketing systems, the inspection reports. A franchisor is not liable for being a brand. A franchisor is liable for the operational and financial entanglement that turns it from a licensor into a partner. The case theory builds the record on the entanglement, not the relationship.
Play 2: “We had no idea.” The hotel says it had no actual knowledge of trafficking at the property. Counter: the law does not require actual knowledge. Constructive knowledge is enough. We put the red-flag checklist in front of a jury — the cash, the door-hangers, the foot traffic, the no-luggage occupant, the prior police calls, the refusals of housekeeping — and we let the jury decide whether a reasonable hotel operator would have noticed. Florida’s mandatory training statute makes the constructive-knowledge argument especially strong in a Florida case, because the law itself assumes that properly trained staff will recognize the indicators.
Play 3: The quick lowball offer with a confidentiality clause. Within weeks of the lawsuit, the carrier or the hotel’s counsel will float a settlement number — often a small fraction of the case’s true value — and tie it to a non-disclosure agreement. The number is engineered to look attractive to a survivor who is exhausted, frightened, and under financial pressure. Counter: we do not let a survivor take a quick lowball without understanding what the case is actually worth. Once a survivor signs a release, the case is over. The carrier knows this. We do the math, we work with life-care planners and forensic economists to value the case properly, and we explain it in plain language before any signature is signed. A free consultation is the first step in making sure a survivor does not leave money on the table by accepting the first number.
Play 4: The blame-the-victim play. The defense will try to imply that the survivor was a willing participant, that she “consented” to the commercial sex, that she was “promiscuous,” or that she was a prostitute who was simply unhappy with the arrangement. Counter: under federal trafficking law and Florida’s civil remedy, consent is legally unavailable when it is coerced by force, fraud, or the particular dynamics of trafficking. The case law is clear. The defense is allowed to make the argument, but we are ready for it, and we will move to strike or limit any argument that crosses the line. The jury will be instructed on the law. The defense’s job is to try to win the argument anyway. Our job is to make sure the argument never gets to the jury on improper ground.
Play 5: Delay and attrition. A trafficking case can take years to resolve. Defense counsel will file motions to dismiss, motions to stay, requests for continuances, and discovery fights at every stage, hoping the survivor runs out of money, energy, or emotional bandwidth. Counter: we do not let the case sit. We set a discovery schedule that runs fast, we file the preservation letter and the spoliation motion the day we are retained, and we keep pressure on the carrier to put real money on the table before trial. We have the resources to stay in the fight. A solo survivor cannot. That is part of why we work on contingency — no fee unless we win.
The Evidence That Exists and How Fast It Disappears
The single biggest mistake a survivor can make in a trafficking case is to wait. Not because of the statute of limitations — the federal window is ten years, and longer for a child victim. The biggest mistake is to wait while the evidence disappears. The proof in these cases lives in records that the hotel is not legally required to keep for very long.
Hotel CCTV and surveillance footage. The cameras that would show a parade of men to a single room, a young woman escorted by the same man for weeks, or a front-desk clerk waving through a familiar face are usually recorded over on a rolling thirty-day loop. There is no federal statute that requires a hotel to keep its video. The retention is set by the property’s own internal policy. Once the loop runs, the footage is gone. The single most important letter our firm sends on day one is a litigation hold and preservation demand, addressed to the hotel, the management company, the franchisor, and the third-party surveillance vendor. After that letter, spoliation is a live issue. If they delete anyway, the jury can be told to assume the missing video would have proven the survivor’s case.
Property management system (PMS) data — key-card logs, guest folios, reservations, payment records, and housekeeping logs. This is the documentary spine of the case. The key-card logs show a room entered dozens of times by a single key, with timestamps. The folios show cash payment after cash payment by the same name, with no charges for incidentals and no pattern of normal guest behavior. The housekeeping logs show “do not disturb” honored for days, no service requests, no charges for towels or damages. None of this is preserved by federal law — retention is governed by the property’s policy and state record-retention requirements, which are often surprisingly short. We demand these records in the same preservation letter.
Police call-for-service and incident history at the address. The local agency’s computer-aided dispatch (CAD) system and incident reports show prior calls to the property. A history of disturbance calls, prior trafficking concerns reported to the police, or prior officer-welfare checks are powerful evidence that the danger was foreseeable and the hotel was on notice. These records are obtained through public-records requests and are subject to the agency’s own retention schedule — typically a few years. We request them early.
Internal employee complaints, incident reports, and brand-inspection records. If staff at the Rodeway Inn ever raised concerns to management and were ignored, those records are gold. Brand-inspection reports from Choice Hotels that documented problems at the property are equally powerful. These documents are controlled by the corporate defendants and have their own retention schedules. They can be quietly destroyed absent a preservation demand. The hold letter freezes them.
The trafficking victim’s own contemporaneous records. The first person the survivor told, the first counselor she saw, the first medical visit, the first police report — these are the records that pin down the timeline and the trauma. They accumulate over time, but the earliest ones are the most powerful. We help survivors identify and preserve them.
Past results depend on the facts of each case and do not guarantee future outcomes.
What a Hotel Trafficking Case Is Worth
The honest answer is: it depends on the facts. The range we work with on cases of this kind runs from a low of about $1,500,000 to a high above $10,000,000, with the upper end driven by the depth of the hotel’s knowledge, the duration of the trafficking, the severity of the harm, and the quality of the evidence. The high valuation in particular is driven by the “deep pockets” of the franchisor defendant and the extreme nature of the trauma. Settlements in the hospitality trafficking space tend to escalate significantly when internal communications show that management ignored specific warnings or that prior police reports were sitting in the property’s files.
A useful benchmark: a 2017 CDC study published in the American Journal of Preventive Medicine estimated the lifetime cost of rape at $122,461 per victim (in 2014 dollars), accounting for medical care, lost productivity, and criminal-justice costs. That figure is only the floor — it does not include pain and suffering, lost earning capacity over a survivor’s working life, or the human cost of the trauma itself. The same study estimated the population economic burden of rape across U.S. adult victims at nearly $3.1 trillion. These are not the numbers we will quote in a demand letter, but they are the numbers that explain why these cases are real and why they are worth fighting.
The damages analysis in a hotel trafficking case typically includes:
- Economic damages — past and future medical and psychological care, lost wages, lost earning capacity, the cost of rebuilding a life that was derailed.
- Non-economic damages — pain and suffering, emotional distress, loss of enjoyment of life, loss of dignity. These are the human losses the legal system cannot put back together but can acknowledge and compensate.
- Punitive damages — designed to punish the wrongdoer and deter the next one. Where the evidence supports a finding that the hotel knew what was happening and kept collecting the cash, punitive damages are central to the case. The $30 million punitive component of the 2025 Georgia motel verdict reflects exactly this principle.
We will not promise a number at the consultation. We will explain the methodology, walk through the categories, and tell you what the evidence in your specific case supports. The number is built, not guessed.
How We Build the Case: Preservation First, Discovery Second, Trial Third
The first move is preservation. The preservation letter goes out the day you call. It names the hotel, the management company, the franchisor, the third-party vendors who hold the surveillance and PMS data, and the local law enforcement agency. It freezes CCTV, key-card logs, folios, housekeeping records, internal incident reports, brand-inspection records, and any employee personnel files for the staff on duty during the relevant period. After that letter, spoliation is a live weapon.
The second move is the federal complaint. The case is filed in the United States District Court for the Southern District of Florida, where it belongs. The complaint pleads the four § 1595 elements and the Florida civil-trafficking claim in the alternative, names all three defendants, and lays out the factual foundation for the constructive-knowledge and operational-control theories that get past Red Roof.
The third move is discovery. We take depositions of the front-desk staff, the housekeeping staff, the general manager, the regional manager, and the brand’s field representative. We subpoena the franchise agreement, the brand-standards manual, the royalty statements, the reservation and marketing data, the prior incident reports, and the property’s prior police-call history. We hire a human-trafficking expert and a hospitality-security expert. We work with a forensic economist to value past and future damages, and a life-care planner to map the survivor’s future psychological and medical needs.
The fourth move is resolution. Most hotel trafficking cases resolve before trial, because the hotel’s insurance carrier does not want a jury to see the surveillance footage, the front-desk log, and the brand-inspection reports. When a case does go to trial, it goes because the carrier has miscalculated what a jury will do when it sees the full picture.
Why a Texas-Based Firm Is Handling Florida Cases
Attorney911 — The Manginello Law Firm, PLLC — is a trial firm that takes Florida cases, working with local Florida counsel or under pro hac vice admission where the court requires it. The firm has been in business since July 18, 2001, with more than $50,000,000 in aggregate recoveries across the practice. We handle hotel and premises liability cases, trucking and 18-wheeler cases, refinery and chemical cases, offshore and maritime cases, construction cases, brain injury and catastrophic injury cases, wrongful death cases, and toxic exposure cases.
This case work is led by Ralph Manginello and Lupe Peña.
Ralph Manginello is the Managing Partner. He has been licensed for 27+ years — admitted to the Texas Bar on November 6, 1998 (Texas Bar #24007597), and admitted to the U.S. 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 was a journalist, and that instinct — to find the facts, to put them in order, to tell the truth of what happened — has never left his practice. He speaks Spanish. He is a member of the State Bar of Texas, the Houston Bar Association, the Harris County Criminal Lawyers Association, the Texas Trial Lawyers Association, the National Association of Criminal Defense Lawyers, and the Pro Bono College of the State Bar of Texas.
Lupe Peña is the second chair on this work and the person whose background makes the difference in cases against institutional defendants. He is a third-generation Texan, born and raised in Sugar Land, with family roots to the King Ranch. He was admitted to the Texas Bar on December 6, 2012 (Texas Bar #24084332) and to the U.S. 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 in 2005. Before joining the firm, Lupe spent years as an insurance defense attorney at a national defense firm — the firm on the other side of the table in cases like this one. He knows the claims-valuation software, the reserve-setting process, the IME-doctor selection, the surveillance playbook, and every delay tactic the carrier is going to run. He now uses that knowledge for survivors. He is fluent in Spanish and conducts full client consultations in Spanish without an interpreter. That matters in trafficking cases, where the survivor’s first language is often Spanish and the ability to tell her story in her own words is not a courtesy — it is part of the case.
The recovery is contingency-based: 33.33% before trial, 40% if the case goes to trial. We do not get paid unless we win. The consultation is free. The same goes for the call that starts the case.
The Filing Window and Why Waiting Is Dangerous
Under 18 U.S.C. § 1595(c), a trafficking survivor has ten years from the date the cause of action arose to file a federal civil-trafficking case. If the survivor was a minor at the time of the trafficking, the ten-year period does not begin to run until her eighteenth birthday. For a survivor trafficked at sixteen, the window can run into her late twenties. For a survivor trafficked at twenty-five, the federal window is open until she is thirty-five.
Florida’s separate civil remedy for human trafficking under Florida Statutes § 772.104 carries its own limitations period. We confirm the exact window at the consultation because state law evolves, and the right statute to bring the claim under depends on the facts and the date of the trafficking.
But the federal window is not the only clock. The evidence clock is shorter and it never stops. By the time a survivor makes the call, the hotel’s surveillance footage may already be gone, the key-card logs may already have been overwritten, and the housekeeping records may already have been purged. That is why the first thing we do is the preservation letter. That is why waiting is dangerous, even when the statute of limitations says you have years.
If you are not sure whether you are within the filing window — call us. We will tell you on the phone, for free.
Frequently Asked Questions
Can I actually sue a hotel chain for what happened to me at a Rodeway Inn?
Yes. The federal Trafficking Victims Protection Reauthorization Act, at 18 U.S.C. § 1595(a), gives a survivor a civil claim against any person or business that knowingly benefited from participation in a trafficking venture. That includes the property owner (Tropical Paradise Resorts), the management company (EZ Hospitality), and the franchisor (Choice Hotels International) — all three named in the federal case filed in the Southern District of Florida. You can also bring a claim under Florida’s own civil remedy for human trafficking at Florida Statutes § 772.104. The hard part is proving the knowledge and participation elements against the franchisor — the Eleventh Circuit’s 2021 Red Roof decision tightened that standard — but the law gives a real path, and the 2025 Georgia motel verdict shows juries are willing to use it.
How long do I have to file a trafficking case in Florida?
Under federal law, you have ten years from the date the cause of action arose, or ten years from your eighteenth birthday if you were a minor when it happened — whichever is later. Florida’s civil remedy for human trafficking has its own statute of limitations, which we will confirm at the consultation. The practical deadline that matters more than the statute of limitations is the evidence deadline: hotel surveillance footage, key-card logs, and housekeeping records disappear on the hotel’s own internal retention schedule, and they do not wait for the statute of limitations. That is why the preservation letter goes out the day you call.
What if the trafficking happened years ago? Is it too late?
Probably not. The federal ten-year window (and the longer window for survivors who were minors at the time) means most survivors who are reading this page are still within the federal filing window. Florida’s civil remedy may also be available. The first conversation we have is a free consultation to confirm which window applies to your case. Even if the statute of limitations is comfortable, the evidence is not — the sooner we move, the more of the hotel’s own records we can preserve.
Do I have to prove the hotel knew what was happening?
You have to prove the hotel knew — or should have known. The legal term is “actual or constructive knowledge.” Constructive knowledge means a reasonable hotel operator would have known based on what was in front of its staff. The red flags — cash payment, refused housekeeping, excessive foot traffic, no luggage, the same man checking in repeatedly, prior police calls — are the industry-trained warning signs. When those signs were there and the hotel kept taking the money, that is constructive knowledge. Florida’s mandatory training statute, Florida Statutes § 509.096, makes this argument especially strong in a Florida case, because the law assumes that a properly trained staff would have recognized the indicators.
What evidence is most important to preserve?
The hotel’s own records. The surveillance video (typically on a thirty-day rolling loop), the key-card access logs, the guest folios and reservation history, the housekeeping and maintenance logs, the incident reports, the employee personnel files for the staff on duty, and the brand-inspection records from Choice Hotels. The local police call-for-service history for the address is also powerful. None of these is preserved by federal law for long. The single most important thing our firm does on day one is the preservation letter to the hotel, the management company, the franchisor, and the third-party vendors who hold the data. If they delete after that letter, spoliation becomes a live weapon at trial.
Who can be sued — the property owner, the management company, or the brand?
All three. They play different roles and the case names them all. The property owner and the management company are the natural targets — they run the building, hire the staff, set the day-to-day routine. The franchisor (Choice Hotels International) is the harder reach, but the case can reach the franchisor when the evidence shows operational control and direct financial benefit beyond a passive franchise relationship. The 2021 Red Roof decision sets the floor, and the 2025 Georgia motel verdict shows that juries will find franchisor liability when the evidence supports it. We name all three from the start.
How much is a hotel trafficking case worth?
The range for cases of this kind runs from about $1,500,000 at the low end to more than $10,000,000 at the high end, with the upper end driven by the depth of the hotel’s knowledge, the duration of the trafficking, the severity of the harm, and the quality of the evidence. Punitive damages — designed to punish and deter — are a central component of the case when the evidence supports a finding that the hotel knew what was happening. A 2017 CDC study estimated the lifetime cost of rape at $122,461 per victim in 2014 dollars, and the population economic burden at nearly $3.1 trillion. We do not promise a number at the consultation — we explain the methodology, the categories, and what the evidence in your specific case supports. Past results depend on the facts of each case and do not guarantee future outcomes.
Will my identity be kept private?
Federal trafficking cases are filed under initials (the South Florida case is filed as “S.W.”), and we will protect the survivor’s identity to the fullest extent the law allows. The complaint and the docket are public, but the courts have tools to protect survivors — pseudonyms, sealed filings, protective orders on discovery. We will pursue every available protection. Confidential settlements are also possible. Your story belongs to you, and we will not let it become spectacle.
Do I have to go to court, or do these cases settle?
Most hotel trafficking cases resolve before trial. The hotel’s insurance carrier does not want a jury to see the surveillance footage and the front-desk log and the brand-inspection reports. A well-built case puts real pressure on the carrier to put real money on the table. When a case does go to trial, it is because the carrier has miscalculated what a jury will do. We prepare every case as if it will be tried, and we have tried them. Either way, the survivor does not pay us anything unless we recover.
What if the trafficker was never arrested or convicted?
The civil case is separate from the criminal case. You do not need a criminal conviction to bring a § 1595 civil action. In fact, many of the strongest civil cases proceed alongside — or in the absence of — a criminal prosecution. The standard of proof in civil court is lower than in criminal court. The hotel’s own knowledge and participation can be proven from its records, its training manuals, its brand standards, and its staff’s behavior, with or without a criminal conviction of the trafficker.
What does the case process look like from the first call to resolution?
The first call is a free, no-pressure conversation to learn what happened and to tell you whether the case fits our practice. If we take the case, we send the preservation letter the same day. We file the federal complaint in the Southern District of Florida, and we serve the defendants. We begin discovery — depositions, document requests, expert retention. The defense will file motions to dismiss and discovery fights at every stage. We push through them. The case typically resolves in a confidential settlement before trial, and when it does not, we try it. From start to finish, the survivor’s role is to tell the truth, to show up for the medical and psychological care that makes the damages real, and to let us do the rest.
Is this something you can do if I am not in Florida anymore?
Yes. We take cases on behalf of survivors regardless of where they live now. The case is filed in the Southern District of Florida because that is where the trafficking happened. You do not need to be in Florida to be the plaintiff, and we work with you remotely on most of the case. Depositions and court appearances can be handled by remote video where the court allows, and we coordinate travel when in-person attendance is required.
Contact a Florida Trafficking Lawyer
If you or someone you love was trafficked at a Rodeway Inn in Dania Beach — or at any motel or hotel in Florida — the first step is a free consultation. There is no cost, no obligation, and no pressure. We will listen, we will tell you honestly what the case looks like, and we will lay out the path.
We do not get paid unless we win. The consultation is free. The preservation letter goes out the day you call. We have the resources to stay in the fight for as long as it takes.
Call 1-888-ATTY-911 (1-888-288-9911).
You can also reach our team directly:
- Ralph Manginello — ralph@atty911.com — attorney profile
- Lupe Peña — lupe@atty911.com — attorney profile
- Office: (713) 528-9070 — contact form
- Cell: (713) 443-4781
Attorney911 — The Manginello Law Firm, PLLC — is a trial firm that takes Florida cases. We work with local Florida counsel and appear pro hac vice where the court requires it. Our practice areas include premises liability and hotel cases, as well as trucking, refinery, offshore, construction, brain injury, wrongful death, and toxic exposure cases. We have been fighting for injured people since 2001, with more than $50,000,000 in aggregate recoveries, on a contingency fee — no fee unless we win.
You can also learn more about how we approach brain injury cases and wrongful death claims on our practice area pages, including the medical and life-care planning work that goes into valuing a catastrophic case. If the trafficking you survived led to injuries that go beyond the psychological — and many do — those pages will tell you how we handle the medical and economic side of the case.
Hablamos Español. Lupe Peña conducts full consultations in Spanish, and we have bilingual staff. When your first language is Spanish, you should not have to tell the most important story of your life through an interpreter. Call us in English or in Spanish. We will be ready.
Past results depend on the facts of each case and do not guarantee future outcomes.
1-888-ATTY-911 (1-888-288-9911). Free consultation. No fee unless we win.