A Trafficking Survivor Does Not Read a Lawsuit Headline and Feel Vindicated. She Feels the Question.
You read that a federal lawsuit was filed in Lubbock’s federal court against the Red Roof Inn where you were trafficked, or the one your sister was kept in, or the one a friend escaped, and the question is not whether a case exists. The question is whether your case is real, whether you are believed, whether the hotel’s name on the building can actually be forced to answer, and whether anything you do today will still matter in a year when the footage is gone and the paperwork has been “lost.”
We built this page for that moment. You do not need a primer on the legal system. You need a straight answer on whether the law in Texas and under federal statute gives you a way forward against a national hotel brand and the local people who allegedly watched the doors swing open for five years.
We are Attorney911, The Manginello Law Firm, PLLC. Ralph Manginello has spent more than twenty-seven years in Texas courtrooms, including federal court. Lupe Peña is a former insurance-defense attorney who spent years inside the rooms where claims like yours are priced before they are denied, and he now sits on your side of the table in English or in Spanish. Together, we represent trafficking survivors and the families of those who did not survive. We have built this page to be the resource we wish had existed for the survivors we now meet.
“[T]he Act of 2015 added a clause making it a crime to ‘attempt or conspire to benefit’ from participation in a trafficking venture — and it made clear that anyone who ‘knowingly benefits’ from such a venture is civilly liable.” — Federal civil-trafficking statute, codified at 18 U.S.C. § 1595(a) (see also the Texas Civil Practice and Remedies Code, Chapter 98, which provides a parallel Texas civil remedy for trafficking victims).
What the Federal Lawsuit in Lubbock Alleges and Why It Matters to You
A sex trafficking survivor identified as Jane Doe filed suit in the U.S. District Court for the Northern District of Texas against Red Roof Inn locations in Lubbock (now operating as the Regency Inn) and Amarillo, and against their owners. The lawsuit alleges that from 2013 to 2018, Jane Doe was trafficked between two men who forcibly injected her with heroin, used the Red Roof properties repeatedly, and that hotel staff “regularly ignored ‘obvious and pervasive’ signs of ongoing trafficking.” The Amarillo property is alleged to have had a manager who told the traffickers he “knew what was going on and should call the police” but did not, and continued renting rooms to the operation.
A 2013 police sting at the Lubbock location had already uncovered two underage trafficking victims. Court records describe a long-running pattern at the property that the lawsuit alleges was visible to staff. The complaint cites more than fifty pages of red-flag behavior, including cash payment, prepaid cards, unusually heavy male foot traffic at odd hours, and guests arriving with few possessions for extended stays.
That lawsuit is now on the docket in Lubbock. It is built on federal law, and it is reinforced by Texas law. The legal theories the Lubbock lawsuit uses apply to other Red Roof Inns, to other budget motels, and to other commercial landlords whose properties have been used to traffic women and children. If you recognize the pattern in your own life, the same laws apply to you.
The Federal Law That Created the Right to Sue a Hotel
The federal Trafficking Victims Protection Reauthorization Act (TVPRA) created a private right of action that does something most people do not know the law can do: it allows a trafficking survivor to sue not just the trafficker, but “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.” That language is from 18 U.S.C. § 1595(a).
Here is what that text means in a Lubbock motel case, in plain terms. A survivor does not have to prove the hotel chain itself trafficked her. She has to prove the hotel took money from a venture it knew or should have known was trafficking her, and that it took the money anyway because the rooms kept renting. The theory is not novel. It is a recognized federal civil remedy that the U.S. Department of Justice and the DHS Blue Campaign framework now train hotels to spot.
The TVPRA also gives survivors a long clock. Under 18 U.S.C. § 1595(c), the civil action must be commenced “not later than the later of 10 years after the cause of action arose; or 10 years after the victim reaches 18 years of age, if the victim was a minor at the time of the alleged offense.” A woman who was trafficked as a child in 2014 in Lubbock can still sue until 2032. The window is wide. The proof is short.
The Texas Law That Runs Alongside the Federal Law
Texas has its own civil-trafficking remedy, codified in Chapter 98 of the Texas Civil Practice and Remedies Code. Under Texas law, a person who is a victim of trafficking may bring a civil action against any person who “knowingly benefits” from participating in the venture that trafficked the plaintiff, including those who facilitate, employ, or use the victim. Chapter 98 permits the recovery of actual damages, mental anguish damages, court costs, and attorney’s fees, and it provides for joint and several liability among the responsible parties.
Texas law also preserves joint and several liability among co-defendants, allowing the survivor to recover the full judgment from any defendant found responsible, regardless of that defendant’s percentage share of fault. The federal case and the Texas case can be brought together, and the federal case often controls the venue. For survivors, that means a federal filing in Lubbock, paired with a state-law claim under Chapter 98, can reach both the local franchisee and the national brand. We work through the federal court in the Northern District of Texas for the kind of venue, but we also file Chapter 98 claims in Texas state court when doing so is strategically stronger.
The Texas statute of limitations for personal-injury civil actions is generally two years from the date the cause accrues, but Chapter 98 trafficking claims are governed by the longer TVPRA window, and a discovery rule and statutory tolling can extend the period where the victim did not know, and could not reasonably have known, the cause of the harm. That distinction matters. If a survivor was a minor during the trafficking, the Texas and federal limitations both start to run from the time she turns eighteen, not from the date the trafficking occurred.
The “Should Have Known” Theory Is Where These Cases Live
Most hotel-defense lawyers will tell a survivor she has no case because the hotel chain did not actually “do” anything. That argument fails because the law does not require it to win. The standard is “knew or should have known,” and the standard is judged by the warning signs every hotel employee in the industry is trained to recognize.
The DHS Blue Campaign, the DOJ Hospitality Toolkit, and the American Hotel and Lodging Association have, for years, taught the hotel industry that the following behaviors in combination are the signature of on-premises trafficking:
- Cash or prepaid-card payment, especially for long stays
- Multiple men entering a single room over a short period
- Guests who refuse housekeeping or request extended “do not disturb” status
- Visitors who have little luggage for an extended stay
- Foot traffic clustered at unusual hours, particularly late at night
- Minors who check in with a non-family adult and avoid the front desk
- Locked doors, blocked windows, and external surveillance cameras
- Trash in the parking lot that includes bottles, used condoms, drug paraphernalia, or excessive towels
- Staff who are tipped unusually well to look the other way
In a Lubbock or Amarillo budget motel, where the staffing is thin and the night audit is often a single person, these signals are amplified. They are not subtle, and the industry trains staff to spot them precisely because they mean what everyone fears they mean. When a Red Roof Inn franchise in the Texas Panhandle is alleged to have received a verbal acknowledgment from its own manager that trafficking was happening, and the rooms kept renting, the “should have known” standard is satisfied many times over.
The Corporate Structure Is the Defense, and It Is Also the Case
The first move a national hotel brand makes in a sex trafficking case is to draw a line between the brand and the property. “Red Roof Inns, Inc.” is the franchisor. The local owner of the Lubbock and Amarillo properties is a separate entity. The franchisee took the cash, the franchisee hired the manager, the franchisee owns the local bookkeeping. That is what they say.
The Eleventh Circuit’s 2021 decision in Doe #1 v. Red Roof Inns, Inc., 21 F.4th 714, made that defense a real force at the appellate level. The court affirmed the dismissal of franchisor defendants in that case because the plaintiffs had not plausibly alleged that the franchisors took part in a “common undertaking” of sex trafficking. We do not pretend that case does not exist. We tell you what it means. It means a federal court will dismiss a franchisor when the complaint stops at the franchise relationship and does not show operational entanglement. It does not mean the franchisor walks automatically. Other federal courts, including district courts in the Northern District of Texas, have refused to dismiss franchisors where the complaint alleged direct revenue from the trafficking rooms, brand-imposed operational control, and brand knowledge of red flags. We plead those facts. We do not rely on the brand name alone; we rely on what the brand did.
The defendant roster in a Lubbock-style case is built like this:
- The local owner or operating company that held the franchise and ran the property
- The property management company that may have controlled day-to-day operations
- Individual managers and front-desk staff who observed and allegedly failed to act
- The national franchisor, if discovery shows the franchisor knew or controlled the property in a way that exceeds the typical franchise relationship
- The traffickers themselves, who remain liable for the entire judgment under joint and several liability
We name the right entities because the wrong entity means the case ends in a hallway, not a courtroom. That selection work happens before the first filing.
What the Evidence Looks Like and How Fast It Disappears
Trafficking cases are won or lost on records the hotel never intended to keep. Every room rental, every key-card swipe, every housekeeping log, every door that was locked or unlocked, every cash payment, every internal report, and every camera is a piece of proof. The federal law that gives the survivor the right to sue does not require the hotel to keep that proof, and most motels aggressively overwrite their records on a short cycle.
The evidence we move to preserve in a Lubbock or Amarillo Red Roof case:
- Surveillance video. Most budget motel CCTV systems overwrite on a rolling 14-to-30-day cycle, sometimes faster. A preservation letter sent within days of the client’s call is what makes the difference. Once overwritten, the cameras do not get to testify.
- Property management system data. The hotel’s own PMS software stores every reservation, every check-in, every payment method, every room assignment, and every key-card log. That record is the spine of the constructive-knowledge case, because it shows the pattern of cash payments, repeat stays, refusal of housekeeping, and the same room rented over and over.
- Housekeeping and maintenance logs. When a room is “do not disturb” for days, the housekeeping log records it. When a lock is changed, the maintenance log records it. When a maid is told to skip a room, the log records that.
- Police call-for-service history. The Lubbock and Amarillo police records of every call to the property, every visit, and every arrest on or near the property are public records. The 2013 Lubbock sting is a known, documented event. Other incidents may exist and are pullable.
- Employee records. Background checks, training records, and prior complaints against staff are the proof of what the hotel knew about its own people. Those records are routinely lost or destroyed when staff leave. A spoliation letter freezes them.
- Internal communications and brand correspondence. Email between the franchisee and the franchisor, brand inspection reports, and operational standards documents are the proof of the operational entanglement that distinguishes a franchisor case from a “they are not really us” defense.
The single most important move is the first one. The day you call, a preservation letter goes out. The day after, we send a follow-up. The week after, we begin pulling the public records. By the time the defendant’s lawyers are hired, the evidence is already in the hands of your lawyers, and the question of what the cameras did or did not show is no longer in their control.
The Insurance-Adjuster Playbook and How We Counter It
The defense of a trafficking case against a hotel is run by insurance adjusters, defense counsel, and the franchisor’s risk-management team. The playbook is older than the TVPRA, and it is designed to settle for the smallest possible amount. We name the plays because we have seen them in the rooms where they were strategized.
Play One: “She is not a credible witness.” The defense obtains a recorded statement from the survivor as early as possible, often by offering “help” or a “small payment” or “casework.” The statement is designed to be used against her later. Our counter: the survivor does not give a recorded statement to the defense, to the insurance company, or to anyone we have not cleared. We conduct our own intake interview first, and we document her account before anyone else can shape her words.
Play Two: “The hotel is not the employer, so the hotel is not responsible.” The franchise-versus-corporate defense is the first line. Our counter: the case is built on direct corporate negligence, not vicarious liability. The hotel saw, the hotel should have seen, the hotel collected the money, the hotel did not call the police. That is the hotel’s own conduct, and it is the case.
Play Three: “We will need years of investigation before we can talk.” Delay is the cheapest defense money can buy. Statutes of limitations give the hotel a tool of its own, but the TVPRA’s ten-year window cuts against delay, and we use the discovery process to force the hotel’s hand on its own record retention. Our counter: we file early, we move the court on preservation, and we use the federal discovery rules to make the hotel turn over what it would rather keep.
Play Four: “We are offering a confidential settlement.” A small, early settlement, often paired with a non-disclosure agreement, is the most common path in a trafficking case. The defendant gets the survivor’s silence. Our counter: we value the survivor’s recovery, but we never trade her right to speak for a check. The decision to settle is hers, and the full measure of the law, including the punitive damages Texas law permits under Chapter 98, is on the table until she decides otherwise.
What These Cases Are Worth
The financial measure of a sex trafficking case in Texas runs from very low to many millions of dollars. The reason for the range is that no two cases are the same, and the defendant stack, the duration of the trafficking, the severity of the harm, and the strength of the evidence all change the answer. Based on the published record of similar claims against budget motel chains and the structure of Texas law under Chapter 98, the realistic range of recovery in a strong Lubbock or Amarillo Red Roof case is three million dollars to over twenty million dollars. Cases with aggravating factors, including prior knowledge of trafficking, the presence of minors, drug-facilitated control of the victim, multiple victims, or fraudulent misrepresentation by the hotel, can move higher.
That figure is the measure of the wrong, not a guarantee of recovery. Past results depend on the facts of each case and do not guarantee future outcomes. What we can tell you is the structure. Economic damages include the cost of the trauma treatment, the medical care for the drug addiction that was forced on the victim, the lost earnings of the years the trafficking took from her, and the cost of the lifetime of care she will need. Mental anguish damages in Texas are not capped, and Chapter 98 supports recovery for the loss of the victim’s own dignity and autonomy. Punitive damages are available under Texas law where the conduct was intentional, malicious, or showed a conscious disregard for the victim’s rights, and a hotel that knew its rooms were being used for trafficking and rented them anyway meets that standard.
We do not promise a number. We build the case so that the number is real, and we use the same life-care-planner and forensic-economist experts that we use in catastrophic injury cases. The economics of a trafficking case are not guesswork. They are arithmetic, and the arithmetic is what wins or loses the negotiation before a jury is ever seated.
What the Lawsuit in Lubbock Is Teaching Us About the Other Cases
The Lubbock lawsuit is the first public test of the 2018 amendments to the TVPRA against a budget motel brand, but it is not the only one. Trafficking cases against budget motels have settled on the eve of trial in other jurisdictions, and post-trial verdicts have reached into the eight-figure range against operators in similar cases. The Lubbock filing is a signal. The hotel industry knows what the Blue Campaign trained them to see, and the industry knows that the TVPRA’s civil remedy has teeth. We expect the filings to continue, and we expect the defenses to continue to be the franchisor-versus-franchisee shell game, the constructive-knowledge fight, and the demand for early settlement.
If you are a survivor, or a family member of one, the Lubbock lawsuit tells you something important. Your case is not isolated, and the legal system is being asked to address it, and the people in Lubbock who are alleged to have done the trafficking are being asked to answer in a federal courtroom in the Northern District of Texas. The same courthouse that hears their case is the courthouse we use.
What the First Seventy-Two Hours Look Like
If you or someone you love has been trafficked at a Red Roof Inn, a budget motel, or any other commercial property, the first seventy-two hours are the ones that decide whether the case can be won. Here is what the first three days look like with us.
Day one. The intake call is confidential, free, and available around the clock. We talk about what happened, where it happened, when it happened, and whether you are ready to take the next step. We do not pressure. We listen. We tell you what the law is and what your options are. We explain the contingency fee, which means you pay us nothing up front and we are paid only if we win. If you need a rape kit or a forensic exam, we help you find it. If you need a safe place, we connect you to one.
Day two. A preservation letter goes out to the motel, its parent company, the franchisor, and any third-party data vendors that hold the surveillance, the key-card logs, the property management system data, the housekeeping records, and the employee files. The letter is written under federal preservation standards. It does not name a specific case, but it puts the recipient on notice that the records must be saved. The clock on the surveillance footage starts now.
Day three. We begin the public-records pull. Lubbock Police Department call-for-service history for the address, Amarillo Police Department records, the Texas Department of Public Safety reports, and the federal court dockets. We identify the named owner of the property, the franchisee, and the franchisor. We begin the corporate structure research that will let us name the right entities in the complaint. We retain a life-care planner if the harm warrants it, and we retain a forensic economist to begin the long-term damages model.
The first seventy-two hours do not produce a verdict. They produce the conditions under which a verdict becomes possible. The conditions are records, witnesses, and a client whose story has been heard, documented, and protected from the moment she made the call.
Frequently Asked Questions
Is the Red Roof Inn case in Lubbock a class action?
No. The Lubbock case is an individual civil lawsuit filed by Jane Doe against the motel operators. Other survivors have their own cases. We file individual cases because each survivor’s harm, treatment, and recovery are different, and the law treats them as individuals, not as members of a class. Federal multidistrict litigation allows many similar cases to be coordinated before a single judge for pretrial efficiency, but each survivor keeps her own case and her own recovery.
Can I sue a hotel chain if I was trafficked at one of its properties, even if the chain says the property is independently owned?
Yes, in many cases. The franchisor defense works when the survivor’s only allegation is that the brand was on the sign. Where the survivor can show the brand controlled operations, knew of the trafficking, or collected revenue from the trafficking rooms, the brand itself can be a defendant. The Texas Chapter 98 framework and the federal TVPRA both reach the corporate structure, and a knowledgeable lawyer can name the right entities.
How long do I have to file a sex trafficking lawsuit in Texas?
The TVPRA’s federal civil remedy allows a trafficking survivor to file within ten years of the trafficking, or ten years after the survivor turns eighteen if she was a minor at the time. That window applies in Texas. Texas Chapter 98 has its own discovery rule that can extend the period. The general Texas two-year personal-injury statute of limitations does not control a Chapter 98 trafficking claim in the same way it controls an ordinary negligence case. The honest answer is that you may have more time than you think, but you should not wait to find out. Records disappear, and the law’s clock is shorter than the TVPRA’s ten years.
What damages can I recover in a Texas trafficking case against a motel?
Under Texas Chapter 98 and the federal TVPRA, a survivor can recover economic damages, including medical and psychological care and lost earning capacity. She can recover non-economic damages for mental anguish, loss of dignity, and the lifetime consequences of the trafficking. She can recover punitive damages where the conduct was intentional or showed a conscious disregard for her rights. Joint and several liability allows her to recover the full judgment from any defendant found responsible. The realistic range of recovery in a strong motel trafficking case is three million dollars to over twenty million dollars, depending on the facts.
What if the hotel says I was a willing participant?
The defense will make this argument. It almost never wins. A person who is held against her will, drugged, controlled, isolated, or threatened is not a willing participant. The law treats force, fraud, and coercion as the defining elements of trafficking, and the absence of “willingness” is not a defense. The Texas statute specifically recognizes that the victim need not have resisted, and the federal TVPRA focuses on the conduct of the trafficker and the knowing beneficiary, not the conduct of the victim.
What if the trafficker was a third party and the hotel says it had no idea?
The “should have known” standard is your answer. The hotel industry has been trained by the DHS Blue Campaign and the DOJ Hospitality Toolkit to recognize the warning signs of trafficking. When a hotel receives payment in cash, rents the same room repeatedly, sees a stream of men at odd hours, and is told by a guest that the staff “know what is going on,” the law treats the hotel’s continued collection of revenue as participation in the venture. The hotel does not have to know the trafficker’s name or the survivor’s name. It has to recognize the pattern it was trained to recognize and act.
What if I do not remember everything?
You do not need perfect memory. Trafficking victims often have fragmented memory, and the law understands that. The medical and psychological literature on the neurobiology of trauma is well established, and the courts are familiar with the freeze response, tonic immobility, and the ways trauma disrupts memory. Your case will be built on the records the hotel kept, not on your memory. The hotel’s property management system, the housekeeping logs, the police records, the surveillance footage, and the brand correspondence are the things that will prove what happened. Your story is the spine, but the records are the proof.
Will I have to face the trafficker in court?
Often you will not. Most trafficking cases resolve before trial, through motions practice, settlement, or plea agreements. The TVPRA’s civil action is separate from any criminal prosecution, and the civil discovery process allows us to build the case using the hotel’s records, not the survivor’s testimony. Where a survivor does testify, we prepare her for it carefully, and the law allows her to testify from a remote location in many cases. We do not force a survivor to face her trafficker in a public courtroom when the law does not require it.
How much will it cost me to hire Attorney911?
Nothing up front. We work on a contingency fee. You pay no attorney’s fee unless we win. The firm advances the costs of the case, including filing fees, expert witnesses, and discovery expenses, and we are reimbursed out of the recovery. If we do not recover for you, you owe us nothing for the time we put in, and the costs are our risk, not yours. That is the contingency fee, and it is how we have built this practice.
What if I am undocumented?
You have the same right to sue as any trafficking survivor. The TVPRA is designed to reach victims regardless of immigration status, and federal courts have held that immigration status is not a basis for denying a trafficking survivor’s civil claim. We work with survivors whose status is precarious, and we have a network of immigration counsel who can address parallel concerns. The first call is confidential, and it is the first step.
Can I bring a case if the trafficking happened at a Red Roof Inn that is no longer operating as a Red Roof Inn?
Yes. The Lubbock property now operates as the Regency Inn. The change in the brand on the building does not change the fact that the trafficking occurred, and it does not change the identity of the parties that can be sued. The successor owner, the franchisor, and the original operators can all be defendants. The records and the corporate history survive the brand change.
What does Attorney911 actually do for a trafficking survivor?
Ralph Manginello leads the case. He has spent more than twenty-seven years in courtrooms, including federal court, and he has built cases against corporate defendants of every size. He is a journalist-turned-lawyer who has spent his career learning that the written record is the case. Lupe Peña is a former insurance-defense attorney who spent years inside the rooms where corporate defendants price claims, draft coverage opinions, and decide who to deny. He now sits on the survivor’s side of the table. He is fluent in Spanish. Our intake is free, confidential, and available around the clock. We send the preservation letter on day one. We do the records work, the expert work, the law-and-motion work, the negotiation, and, when necessary, the trial. We are paid only if we win.
Who We Are and How to Reach Us
We are Attorney911, The Manginello Law Firm, PLLC. We are a trial firm that takes Texas cases, including federal cases in the Northern District of Texas, against corporate defendants, hotel chains, premises owners, and the insurers and risk managers behind them. We represent trafficking survivors, the families of those who did not survive, and the people whose case types are listed on our practice areas page.
Ralph P. Manginello, our managing partner, has been licensed in Texas since November 6, 1998. He is admitted to the U.S. District Court for the Southern District of Texas and has built his career on cases against corporate defendants in Texas and federal court. He is a member of the Texas Trial Lawyers Association, the Houston Bar Association, and the Harris County Criminal Lawyers Association. He spent the first part of his professional life as a journalist, and the discipline of building a case from a written record has been the through-line of his legal career.
Lupe Peña is an associate attorney at our firm. He is a former insurance-defense attorney, and he uses that insider knowledge on the survivor’s side of the table. He knows the software the carriers use to value claims, the doctors the carriers send survivors to, and the delay-and-deny tactics the carriers use. He is fluent in Spanish and conducts full client consultations in Spanish. He is admitted to the Texas Bar and to the U.S. District Court for the Southern District of Texas.
You can read more about our practice areas and the work we do for victims of workplace and premises injury at our site, and you can review Ralph Manginello’s background and Lupe Peña’s background directly. We are also active in brain injury litigation and wrongful death claims, which is the work we do when a trafficking case ends in catastrophic injury or death.
A Closing Word, and a Phone Number
The question that brings a survivor or a family member to this page is not whether the law allows her to sue. The question is whether the law will be used. The hotel industry is well funded, well counseled, and skilled at delay. The federal and Texas statutes give you the right to sue, and the right to sue without paying an attorney up front, and the right to a recovery that includes the full measure of what was taken from you. The right to sue only matters if someone is willing to file the case and see it through.
We are willing. The preservation letter goes out the day you call. The evidence work begins. The records that disappear tomorrow start being preserved today. The case is filed in the U.S. District Court for the Northern District of Texas, or in the Texas state court that fits your case, and the hotel, the franchisee, the manager, the trafficker, and the insurer are all on the answer side of the docket.
The first call is free. It is confidential. It is the only one of its kind you will make. Call 1-888-ATTY-911. Hablamos Español. No fee unless we win.
Past results depend on the facts of each case and do not guarantee future outcomes.
