A Wisconsin federal court dismissed Trafficking Victims Protection Reauthorization Act (TVPRA) claims against Choice Hotels (franchisor of the Comfort Suites brand) and its franchisee, hotel operator App Pro. Doe v. Choice Hotels Int’l, Inc., 2026 WL 3026402 (E.D. Wisc. Oct. 8, 2026). The plaintiff alleged she was a victim of sex trafficking at a Comfort Suites hotel in Appleton, Wisconsin, contending that App Pro had constructive knowledge of various “red flags” of trafficking occurring on the property and facilitated the trafficking venture by continuing to rent rooms to her traffickers. She brought claims under the TVPRA against App Pro for perpetrator liability, both App Pro and Choice for beneficiary liability, and Choice for vicarious liability.
The court dismissed the complaint in its entirety, holding that the plaintiff failed to plausibly allege that App Pro had constructive knowledge of her alleged trafficking. Although the plaintiff identified various “red flags,” including cash payments, frequent visitors, and signs of drug use, the court found those allegations suggested only possible commercial sex activity. The plaintiff did not allege facts suggesting that she was being held against her will or subjected to sex trafficking by force, fraud, or coercion, as required for an adult to state a claim under the TVPRA. Rather, she argued that signs of commercial sex should be treated as signs of sex trafficking. The court disagreed. The court further held that the plaintiff failed to allege facts showing that App Pro knowingly participated in a trafficking venture, as the complaint did not plausibly allege a continuous business relationship with the traffickers or any conduct demonstrating culpable participation in the alleged venture. Because the claims against App Pro failed, the plaintiff’s vicarious liability claim against Choice likewise failed.
In addition, the court held the plaintiff’s beneficiary liability claim against Choice failed because the plaintiff did not sufficiently “connect the dots” between the alleged trafficking and the franchisor. Noting that a franchisor typically cannot observe alleged signs of sex trafficking, the court determined that “a beneficiary claim against a franchisor requires the plaintiff to allege that the franchisor received notice that the trafficking venture was occurring at its property.” The plaintiff did not do so, and the beneficiary liability claim failed.