Levin Papantonio: Federal Judge Denies Hotel Chains’ Motions for Summary Judgment in Landmark Human Trafficking Case

COLUMBUS, Ohio, Sept. 26, 2025 (GLOBE NEWSWIRE) --  Chief Judge Algenon L. Marbley of the U.S. District Court for the Southern District of Ohio rejected efforts by hotel defendants to escape liability in a federal human trafficking case (Civil Action 2:19-cv-00849).

In a Court Opinion and Order filed Monday, September 22, 2025, Judge Marbley emphasized that the case centers on whether hotels that rented rooms to traffickers can be held responsible under the Trafficking Victims Protection Reauthorization Act (TVPRA). He explained that the statute was written to hold accountable not only traffickers themselves, but also those who facilitate the industry.

Judge Marbley further underscored the critical role hotels play in trafficking operations:

“In the sex trafficking industry, that infrastructure begins and ends with physical spaces. Sex trafficking ventures cannot operate without access to physical spaces. So, it follows that providing traffickers with a room is providing them with an essential place of business. That is participation. This is not a radical take. Without the room, there would be no trafficking.”

The Court went on to clarify:

“The relevant question is not what Defendants generally knew or understood about signs of human trafficking. It is, at a minimum, what they should have known based on the totality of the circumstances and the information available to them.”

On that basis, on September 22, 2025, the Court denied summary judgment motions from multiple hotel defendants, allowing the case to proceed to trial.

Plaintiff’s Perspective

Attorneys for the plaintiff say Judge Marbley’s order further clarifies the intent of the TVPRA: hotel corporations cannot turn a blind eye when their properties become sites of human trafficking. The case represents years of legal work to hold the hospitality industry accountable for benefitting from exploitation while ignoring red flags.

Kim Adams, Levin Papantonio attorney and a member of the plaintiff’s legal team, called the decision a critical step in assuring that the voices of trafficking survivors are heard.

“This ruling validates what survivors and advocates have been saying for years. Hotels are not passive bystanders when traffickers rent rooms day after day. They provide the very spaces that make this criminal industry possible."

Adams added that allowing the case to proceed to trial is critical not only for the plaintiff but also for the broader effort to force industry change.

“Our client’s courage has already changed the law in ways that will protect others. This ruling will reverberate throughout the hospitality industry. Judge Marbley has made it plain that ignoring trafficking is not a defense. We look forward to presenting our client’s story to a jury and proving the full extent of the defendants’ responsibility.”

Plaintiff’s Allegations and Experiences

The plaintiff, identified as M.A., endured sex trafficking at hotels for more than a year. She testified that her traffickers subjected her to physical and psychological abuse, including repeated beatings, food deprivation, threats that her body would never be found, and isolation from her family.

In 2019, M.A. brought this civil action under the TVPRA, alleging that the hotels where she was trafficked knowingly benefitted by renting rooms to her traffickers while ignoring obvious indicators of trafficking.

The Court’s Analysis of TVPRA Elements

In denying summary judgment, Judge Marbley evaluated three key elements under Section 1595 of the TVPRA.

Element One: Knowingly Benefitted
The Court held that renting a room to traffickers constitutes a financial benefit under the statute. Evidence that defendants received a benefit, including the cost of the room where trafficking occurred, is sufficient to satisfy this element. Arguments that “actual knowledge” of trafficking is required were rejected. The statute requires only that defendants knowingly received the financial benefit.

Element Two: Participation in a Venture
Judge Marbley reaffirmed that providing traffickers with a room may equate to participation in a venture. He emphasized that “without the room, there would be no trafficking.” Questions about defendants’ level of participation are factual matters for a jury.

Element Three: Knew or Should Have Known
The Court stressed that liability requires either actual or constructive knowledge that rooms were being used for trafficking. The standard is negligence-based, meaning that hotel operators are accountable if they should have recognized signs of trafficking based on the circumstances. Judge Marbley noted that knowledge is “a fact-intensive inquiry best reserved for the jury,” underscoring that these cases hinge on evidence a jury must weigh.

A Landmark Step Toward Accountability
The Court’s ruling not only allows M.A.’s claims to proceed but also signals a turning point in how the law applies to corporations that benefit while enabling human trafficking. For the plaintiff’s legal team, this is about more than one case.

“Survivors deserve the chance to have their stories heard in front of a jury. This is about justice for our client, but it is also about forcing an industry to change its practices, so this does not happen to others,” Adams said.

Plaintiff, M.A. is represented by Levin Papantonio, Zarzaur Law Firm, and Babin Law, LLC.

About Levin Papantonio

The Levin Papantonio law firm has been representing injured people across the globe since 1955. The firm has gained national recognition as one of the most successful personal injury firms in the world and has been featured on CNN, NBC, ABC, CBS, and Fox, as well as in The Wall Street Journal, The New York Times, The Washington Post, Time Magazine, Forbes, and the National Law Journal.

LP attorneys handle lawsuits throughout the country and have helped obtain more than $80 billion in jury verdicts and settlements, litigating against some of the largest corporations in the world.

A photo accompanying this announcement is available at https://www.globenewswire.com/NewsRoom/AttachmentNg/3e011f7f-5523-4ee5-8c5d-c965cd312566

MEDIA CONTACT:
Sara G. Stephens
Director of Content and Communications
Levin Papantonio
281-744-6560
sstephens@levinlaw.com

hotels that rent rooms to traffickers

The case of M.A., a sex trafficking survivor who aims to hold hotels accountable for renting rooms to traffickers, can proceed to trial after a federal judge's ruling.

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