Doe v. Choice Hotels International , Inc.

District Court, D. Maryland·Decided August 22, 2025·No. 8:24-cv-02836·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

JANE DOE (C.T.K), *

Plaintiff, *

v. * Civ. No. DLB-24-2836

CHOICE HOTELS INTERNATIONAL, * INC., et al., * Defendants.

MEMORANDUM OPINION Plaintiff Jane Doe alleges that she was the victim of sex trafficking at a Comfort Suites hotel in Appleton, Wisconsin. The Appleton Comfort Suites is operated by App Pro of Appleton, Inc. (“App Pro”), which is a franchisee of Choice Hotels International, Inc., a corporation with its principal place of business in Rockville, Maryland. Doe sued Choice Hotels International, Inc., Choice Hotels International Service Corp. (collectively, “Choice Hotels”), and App Pro, alleging violations of the Trafficking Victims Protection Reauthorization Act (“TVPRA”), 18 U.S.C. §§ 1581 et seq. Choice Hotels and App Pro move to dismiss Doe’s complaint. Both of them argue that this case should be dismissed because venue in this district is improper and Doe fails to state a claim upon which relief can be granted. Choice Hotels argues alternatively that this case should be transferred to the Eastern District of Wisconsin. App Pro makes the additional argument that the claims against it should be dismissed because this Court lacks personal jurisdiction over it. For the following reasons, Choice Hotels’ motion to transfer is granted. This action is transferred to the U.S. District Court for the Eastern District of Wisconsin. The motions to dismiss for improper venue and personal jurisdiction are denied as moot. The motions to dismiss for failure to state a claim remain pending. I. Background C.T.K., proceeding anonymously as Jane Doe, filed this suit against App Pro and Choice Hotels on October 1, 2024. These are the facts as Doe alleges them in her amended complaint. Jane Doe was “trafficked through force and coercion by her trafficker to engage in

numerous commercial sex acts.” ECF 19, ¶ 30. Doe’s trafficker pretended to be her boyfriend. Id. Under the pretense of a romantic relationship, he forced Doe to become addicted to drugs and coerced her into participating in commercial sex acts. Id. Doe’s trafficker trafficked her from January 2014 until December 2015. Id. During that period, from July 1, 2014 until March 31, 2015, Doe was trafficked at the Comfort Suites hotel in Appleton, Wisconsin, which is owned by App Pro. Id. App Pro is a franchisee of Choice Hotels. Id. ¶ 23. Doe alleges that she was “trafficked an incalculable number of times” at the Appleton Comfort Suites. Id. ¶ 32. Doe claims that App Pro and Choice Hotels facilitated her trafficking. Id. ¶ 31. Doe alleges that, due to the prevalence of human trafficking in hotels, App Pro and Choice Hotels were both educated and trained on the “red flags” of sex trafficking, such as possession or

use of multiple cell phones; lack of control over money or IDs; and “signs of malnourishment, poor hygiene, fatigue, sleep deprivation, untreated illness, injuries, and/or unusual behavior.” Id. ¶¶ 37–39. According to Doe, the defendants “were aware or should have been aware of these signs of sex trafficking when operating, controlling, and managing their hotel properties, when enacting and enforcing policies and procedures applicable to those hotels and when training, educating, and supervising the staff of th[e] hotel[s].” Id. ¶ 42. She claims App Pro and Choice Hotels had a responsibility to develop policies and staff trainings to prevent sex trafficking at their hotel but failed to do so. Id. ¶¶ 46–47, 80. Doe also claims that App Pro and Choice Hotels knew about the prevalence of sex trafficking at Choice Hotels branded properties. Id. ¶ 48. Doe identifies a dozen news stories about sex trafficking at Choice Hotels branded properties. Id. ¶ 50. She alleges that Choice Hotels monitors reviews of its properties, and she points to 21 reviews of Choice Hotels properties on

Expedia, Google, Trip Advisor, Yelp, each complaining about prostitution happening at the hotels. Id. ¶ 51. According to Doe, these reviews and news stories show that Choice Hotels knew that “[t]he use of its branded properties for sex trafficking was not limited to one location or geographic region but was a widespread problem,” “[i]ts franchisees and hotel staff were not taking reasonable steps to identify, report, and respond to known or probable sex trafficking occurring at its hotel properties,” and “[i]t was, by its acts and omissions, facilitating sex trafficking at its branded properties by providing venues where the trafficking was occurring widely and without sufficient detection or deterrence.” Id. ¶ 52. Next, Doe claims that Choice Hotels and App Pro knew that sex trafficking was prevalent at the Appleton Comfort Suites. First, the Comfort Suites “was in a high-crime area with a known

history of reports of sex trafficking.” Id. ¶ 55. Next, the Outagamie County Sheriff’s Office “regularly w[as] involved at the subject Comfort Suites from July 1, 2014 to March 31, 2015 for calls regarding sex offenses, illegal drugs, and harassment—all signs of illegal sex trafficking.” Id. ¶ 56. Doe was not the first trafficking victim to be trafficked at the Appleton Comfort Suites; she alleges that other trafficking victims were exploited at the Appleton Comfort Suites before her, and hotel staff and management ignored obvious “red flags” of their trafficking. Id. ¶¶ 57–58. Additionally, Doe claims that App Pro and Choice Hotels knew or should have known about the widespread trafficking at the Appleton Comfort Suites based on non-public sources like internal investigations, customer complaints, surveillance and security systems, and information from law enforcement. Id. ¶¶ 60–61. She claims that, upon information and belief, App Pro “report[ed] numerous instances of suspected sex trafficking to Choice Hotels before and during [her] trafficking.” Id. ¶ 63. Doe also alleges that Choice Hotels and App Pro knew or should have known that she was

being trafficked at the Appleton Comfort Suites. She points to the following “obvious signs that her traffickers were engaged in sex trafficking”: a. The hotel rooms in which she was trafficked were frequently paid for with cash or prepaid cards; b. Other girls were trafficked at the same hotel at the same time as [her]; c. [She] and her traffickers would stay for multiple times between July 1, 2014 through March 31, 2015[;] d. The front desk gave her trafficker a specific room for them to stay[;] e. [She] asked for clean sheets and towels multiple times a day[;] f. The traffickers were often present with [her] at check in; g. There was heavy foot traffic in and out of [her] room involving men who were not hotel guests; h. [She] had around twenty (20) johns every day. These individuals entered and left at unusual hours and were present at the hotel for brief periods of time; and i. Other obvious signs of trafficking consistent with the modus operandi of her traffickers and which included well known ‘red flags’ for trafficking in a hotel.

Id. ¶ 65. Based on these signs, Doe alleges, App Pro knew about or was willfully blind to Doe’s trafficking. Id. ¶¶ 66, 67. Choice Hotels also knew or should have known about Doe’s trafficking. Id. ¶¶ 68, 69. But neither defendant did anything to stop it. Instead, App Pro and Choice Hotels continued to rent rooms to Doe’s traffickers. Id. ¶¶ 73–74, 78–79. According to Doe, Choice Hotels, App Pro, and sex traffickers, including Doe’s traffickers, were engaged in a “venture” at the Appleton Comfort Suites. Id. ¶ 82. Choice Hotels and App Pro both “received benefits, including increased revenue, every time a room was rented at the Comfort Suites.” Id.

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

Doe v. Choice Hotels International , Inc., (D. Md. 2025).

Doe v. Choice Hotels International , Inc. (Doe v. Choice Hotels International , Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Hoffman v. Blaski
363 U.S. 335 (Supreme Court, 1960)
Stewart Organization, Inc. v. Ricoh Corp.
487 U.S. 22 (Supreme Court, 1988)
Sorcia v. Holder
643 F.3d 117 (Fourth Circuit, 2011)
CoStar Realty Information, Inc. v. Meissner
604 F. Supp. 2d 757 (D. Maryland, 2009)
Mamani v. Bustamante
547 F. Supp. 2d 465 (D. Maryland, 2008)
Board of Trustees v. Sullivant Avenue Properties, LLC
508 F. Supp. 2d 473 (E.D. Virginia, 2007)
Ulman v. Boulevard Enterprises, Inc.
638 F. Supp. 813 (D. Maryland, 1986)
D2L LTD. v. Blackboard, Inc.
671 F. Supp. 2d 768 (D. Maryland, 2009)
Corry v. CFM Majestic Inc.
16 F. Supp. 2d 660 (E.D. Virginia, 1998)
Lynch v. Vanderhoef Builders
237 F. Supp. 2d 615 (D. Maryland, 2002)
Cronos Containers, Ltd. v. Amazon Lines, Ltd.
121 F. Supp. 2d 461 (D. Maryland, 2000)
Helsel v. TISHMAN REALTY & CONST. CO., INC.
198 F. Supp. 2d 710 (D. Maryland, 2002)
Tyler v. Gaines Motor Lines, Inc.
245 F. Supp. 2d 730 (D. Maryland, 2003)
Darlene Gibbs v. Sequoia Capital Operations
966 F.3d 286 (Fourth Circuit, 2020)
CareFirst, Inc. v. Taylor
235 F. Supp. 3d 724 (D. Maryland, 2017)
Pinpoint IT Services, L.L.C. v. Atlas IT Export Corp.
812 F. Supp. 2d 710 (E.D. Virginia, 2011)