CHICAGO (LN) — A federal judge in the Northern District of Illinois allowed sex trafficking survivors’ claims against several Chicago-area hotels and their franchisors to proceed under the Trafficking Victims Protection Reauthorization Act, denying most motions to dismiss.
U.S. District Judge LaShonda A. Hunt ruled on May 8 that the plaintiffs plausibly alleged the hotel operators and franchisors knowingly harbored the women or financially benefited from their sex trafficking between 2015 and 2016.
The plaintiffs, who were trafficked by a man identified as "Block," alleged they were forced to engage in commercial sex at multiple hotels across the Chicago metropolitan area. They claimed hotel staff observed "red flags" including visible bruises, cash payments, extended stays, and frequent male visitors, yet continued to rent rooms.
Hunt rejected the defendants' argument that the complaint was an impermissible "shotgun pleading," finding the document provided fair notice of the claims against each defendant.
The court denied motions to dismiss for Polanin Investments Corp. (Super 8), SBY Downers Grove LLC (Comfort Inn/Best Western), ESA P Portfolio LLC (Extended Stay), Litchfield Motel Inc. (Lexington Inn), and Courtyard Management LLC (Courtyard Arlington).
Hunt granted Marriott Hotel Services LLC's motion to dismiss entirely, finding the plaintiffs failed to allege facts supporting that Marriott staff knew the women were trafficking victims. The court also dismissed claims against Courtyard Management LLC regarding the Courtyard by Marriott Chicago-Elgin-West Dundee location, citing "barebones and conclusory allegations," but allowed claims to proceed regarding the Courtyard Arlington location.
For the franchisor defendants, Hunt dismissed direct liability claims against Choice Hotels International Inc., Super 8 Worldwide Inc., and ESH Strategies Franchise LLC. However, she allowed indirect liability claims to proceed, ruling that the plaintiffs plausibly alleged the franchisors controlled franchisee operations through brand standards, training, and hiring policies, creating an agency relationship.
The court also allowed the plaintiffs' claim under the Illinois Trafficking Victims Protection Act to proceed against ESA P and ESH, finding they plausibly alleged the hotels knowingly charged higher rates to the trafficker.
Hunt dismissed all claims without prejudice, noting that amendment would not be futile.
Defendants must answer the surviving claims by May 29, 2026, and file a joint proposed discovery plan by June 5, 2026.