Doe (S.S.) v. Red Roof Inns, Inc.

CourtDistrict Court, S.D. Ohio
DecidedFebruary 27, 2025
Docket2:24-cv-01780
StatusUnknown

This text of Doe (S.S.) v. Red Roof Inns, Inc. (Doe (S.S.) v. Red Roof Inns, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Doe (S.S.) v. Red Roof Inns, Inc., (S.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

JANE DOE (S.S.),

Plaintiff, Civil Action 2:24-cv-1780 Judge Algenon L. Marbley v. Magistrate Judge Elizabeth P. Deavers

RED ROOF INNS, INC., et al.,

Defendants. OPINION AND ORDER This matter is before the Court on Defendants Red Roof Inns, Inc., Red Roof Franchising, LLC, RRF Holding Company, LLC, and RRI West Management, LLC’s (“RRI Defendants”) Motion to Transfer Venue. (ECF No. 22.) For the reasons stated herein, RRI Defendants’ Motion is DENIED.1 I. BACKGROUND Plaintiff S.S., a resident of Kentucky, alleges that she was trafficked for sex between March and April 2017 at the Varahi Hotel LLC d/b/a Red Roof Inn (“Red Roof Inn”) located in Smyrna, Georgia, a franchise of RRI Defendants. (Compl., ECF No 1, at ¶¶ 24–33.) Defendants Red Roof Inns, Inc., RRF Holding Company, LLC, and Red Roof Franchising, LLC each have their principal place of business in the Southern District of Ohio. (Id. at ¶¶ 12–14.) Defendant RRI West Management’s registered agent is located in Cleveland, Ohio, and is an affiliate of

1 Plaintiff filed a Notice of Supplemental Authority. (ECF No. 32.) RRI Defendants filed a Motion for Leave to File a Response to Plaintiff’s Notice. (ECF No. 37.) The Court DECLINES to consider Plaintiff’s Notice and DENIES as moot RRI Defendants’ Motion for Leave (ECF No. 37). Further, Plaintiff’s request for oral argument is DENIED. (ECF No. 29.) Red Roof Inns, Inc. and Red Roof Franchising, LLC. (Id. at ¶ 15.) On April 15, 2024, Plaintiff filed this action seeking to hold Defendants liable under the Trafficking Victims Protection Reauthorization Act (“TVPRA”), 18 U.S.C. § 1595(a). (Id. at ¶¶ 4, 6–7.) Plaintiff alleges that RRI Defendants knew that sex trafficking occurred on their property, they facilitated and benefitted from Plaintiff’s sex trafficking, and they knew or should have

known of Plaintiff’s sex trafficking. (Id. at ¶¶ 6–7, 29–30, 50.) Plaintiff asserts that RRI Defendants “failed to take appropriate action in response to their knowledge of widespread and ongoing human trafficking in their hotels.” (Id. at ¶ 50.) Further, Plaintiff contends that there were obvious signs of her trafficking, including “that hotel rooms would be paid for in cash or prepaid card,” she did not leave the room, “she had few or no personal items, the do not disturb sign was constantly on the door . . .[,] and there was a constant heavy foot traffic in and out of her room involving men who were not hotel guests.” (Id. at ¶ 32.) RRI Defendants moved this Court to transfer this case to the United States District Court for the Northern District of Georgia pursuant to 28 U.S.C. § 1404(a). (Mot., ECF No. 22.)

Plaintiff filed a response in opposition (Resp., ECF No. 29.) RRI Defendants filed a reply brief in support of their Motion. (ECF No. 40.) This matter is ripe for judicial review. II. STANDARD OF REVIEW Under 28 U.S.C. § 1404(a), “[f]or the convenience of parties and witnesses, in the interest of justice, a district court may transfer any civil action to any other district or division where it might have been brought.” The threshold issue under § 1404(a) is whether the action could be brought in the transferee court. Kay v. Nat’l City Mortg. Co., 494 F. Supp. 2d 845, 849 (S.D. Ohio 2007). If a case could be brought in the transferee court, “the issue becomes whether transfer is justified under the balance of the language of § 1404(a).” Id. In balancing convenience, the Court must consider factors such as “the private interests of the parties, including their convenience and the convenience of potential witnesses, as well as other public- interest concerns, such as systemic integrity and fairness, which come under the rubric of ‘interests of justice.’” Moore v. Rohm & Haas Co., 446 F.3d 643, 647 n.1 (6th Cir. 2006) (quoting Moses v. Bus. Card Exp., Inc., 929 F.2d 1131, 1137 (6th Cir. 1991)). Relevant private interest factors to consider include the following: “(1) the plaintiff’s choice of forum; (2) where

the parties reside; (3) the location of willing and unwilling witnesses; (4) the location of evidence; and (5) the locus of events that gave rise to the dispute.” Olin-Marquez v. Arrow Senior Living Management, LLC, 586 F. Supp. 3d 759, 776 (S.D. Ohio 2022) (internal citations omitted). Relevant public interest factors include: “(1) the court’s interest in judicial economy; (2) docket congestion; (3) local interest in deciding the controversy at home; (4) the public’s general interest in systemic integrity and fairness; and (5) the court’s familiarity with the governing law.” Id. at 778 (citing Youngblood v. Life Ins. Co. of N. Am., No. 3:16-CV-34, 2016 WL 1466559, at *1 (W.D. Ky. Apr. 14, 2016)). The moving party bears the burden to establish a need for transfer. Kay, 494 F. Supp. 2d

at 849–50 (citing Jamhour v. Scottsdale Ins. Co., 211 F. Supp. 2d 941, 945 (S.D. Ohio 2002)). Transfer pursuant to § 1404 must be “to a more convenient forum, not to a forum likely to prove equally convenient or inconvenient.” Van Dusen v. Barrack, 376 U.S. 612, 645–46 (1964); see also Shanehchian v. Macy’s, Inc., 251 F.R.D. 287, 292 (S.D. Ohio 2008) (“[Section] 1404 does not allow . . . for transfer if that transfer would only shift the inconvenience from one party to another.”). Even where venue is proper, a district court may exercise its broad discretion to transfer a civil action to a more convenient forum pursuant to § 1404(a). See Reese v. CNH Am. LLC, 574 F.3d 315, 320 (6th Cir. 2009) (citing Phelps v. McClellan, 30 F.3d 658, 663 (6th Cir. 1994)). “Ultimately . . . the decision whether to transfer venue under § 1404(a) is committed to the sound discretion of the trial court.” Levy v. Cain, Watters & Assocs., P.L.L.C., No. 2:09-cv-723, 2010 WL 271300, at *9 (S.D. Ohio Jan. 15, 2010); Reese, 574 F.3d at 320 (“As the permissive language of the transfer statute suggests, district courts have broad discretion to determine when party convenience or the interest of justice make a transfer appropriate.”) (quotation omitted).

III. ANALYSIS In front of the Court, yet again, is the issue of venue in a TVPRA case where the corporate defendants—Red Roof Inns, Inc. and its related corporate entities—are located in the Southern District of Ohio.2 As Plaintiff notes, however, RRI Defendants fail to acknowledge, much less distinguish, the Court’s numerous TVPRA decisions on venue.3 (Resp., at PageID 350–51, 353–54.) As a result, RRI Defendants’ Motion requires minimal analysis. RRI Defendants fail to persuade the Court that it should reach a different outcome in this case. RRI Defendants argue that the Northern District of Georgia is the more convenient venue and the “public interest in the administration of justice on balance favors transfer . . . .” (Mot. at PageID 238–41.) While each case presents unique circumstances, this Court has already

explained that it also must “consider the impact of transferring these cases as a whole, and not in isolation.” In re Hotel TVPRA Litig., No. 2:22-CV-1924, 2023 WL 3075851, at *21 (S.D. Ohio Apr. 25, 2023).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Van Dusen v. Barrack
376 U.S. 612 (Supreme Court, 1964)
Angela M. Phelps v. John D. McClellan
30 F.3d 658 (Sixth Circuit, 1994)
Reese v. CNH AMERICA LLC
574 F.3d 315 (Sixth Circuit, 2009)
Kay v. National City Mortgage Co.
494 F. Supp. 2d 845 (S.D. Ohio, 2007)
Jamhour v. Scottsdale Insurance
211 F. Supp. 2d 941 (S.D. Ohio, 2002)
Moore v. Rohm & Haas Co.
446 F.3d 643 (Sixth Circuit, 2006)
Shanehchian v. Macy's, Inc.
251 F.R.D. 287 (S.D. Ohio, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
Doe (S.S.) v. Red Roof Inns, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/doe-ss-v-red-roof-inns-inc-ohsd-2025.