A Florida federal court recently dismissed a claim alleging Wyndham Hotels & Resorts, franchisor of the Days Inn brand, violated the Trafficking Victims Protection Reauthorization Act (TVPRA). Weiner v. Wyndham Hotels & Resorts, Inc., 2026 WL 925619 (S.D. Fla. Apr. 6, 2026).
The plaintiff alleged she was trafficked for commercial sex acts at a Days Inn franchised hotel and that Wyndham knew the hotel was a hub for prostitution and trafficking. The plaintiff further alleged that Wyndham’s franchise revenue model created a direct financial incentive for it to ignore the criminal activity. The court nevertheless dismissed the plaintiff’s TVPRA claim against Wyndham. To state a TVPRA claim against Wyndham, the plaintiff was required to allege facts indicating that Wyndham “participated” in a sex trafficking venture. The court held that the plaintiff failed to do so; her allegations that Wyndham accepted revenue from a franchisee that may have actively been participating in sex trafficking and failed to stop the franchisee were not enough to plead “participation in a venture” under Eleventh Circuit law. Accordingly, the court dismissed the plaintiff’s TVPRA claim against Wyndham even though the court found the plaintiff had adequately alleged Wyndham had, at least, constructive knowledge of trafficking at Days Inn, based on visible trafficking indicators, corporate oversight, and internal monitoring systems. After dismissing the TVPRA claim, the court declined to exercise supplemental jurisdiction over the plaintiff’s vicarious liability claim, dismissing the case in its entirety.