CHICAGO (LN) — A federal judge refused Thursday to dismiss most claims against a group of Chicago-area hotels accused of harboring two women who were sex trafficked across at least seven properties from 2011 through 2017, holding that the plaintiffs had plausibly alleged that staff watched the abuse unfold and kept renting rooms anyway.
U.S. District Judge LaShonda A. Hunt's ruling in Emily T. and Amanda D. v. SBY Downers Grove et al. allows perpetrator-liability claims under the federal Trafficking Victims Protection Reauthorization Act to proceed against five hotel operators: SBY Downers Grove (Comfort Inn), Polanin Investments (Super 8), ESA P Portfolio (Extended Stay), Litchfield Motel (Lexington Inn & Suites), and Courtyard Management with respect to the Courtyard Arlington Heights South. The ruling also revives beneficiary-liability claims against franchisors Choice Hotels International and Super 8 Worldwide on indirect-liability theories. All claims against Marriott Hotel Services and claims tied to the Courtyard by Marriott Chicago Elgin-West Dundee were dismissed.
The complaint describes a trafficking operation run by a man identified only as "Block," who, according to the complaint, forced the two women to service clients at each hotel, sometimes for weeks at a stretch, paying for rooms in cash and requesting back-of-the-building accommodations. According to the complaint, the women typically wore revealing clothing regardless of the weather, bore visible bruises from Block's beatings, left used condoms and lubricant packets in their rooms, and received a stream of male visitors that staff could not have missed.
At the Comfort Inn in Downers Grove — owned and operated by SBY — the complaint alleges Block "called the hotel 'his stomping grounds'" and "had a connection with an employee at the Comfort Inn who was aware that he was a pimp and coercing girls to engage in commercial sex acts." In a typical month, the complaint says, more than 100 different men entered and exited the plaintiffs' room. When a hotel employee noticed Emily's severe bruising one morning and asked if she was okay, the complaint says Emily replied with a stiff "yes" and turned a cold shoulder, but the employee took no further action.
At the Extended Stay in Schaumburg, the complaint alleges staff went further: they alerted the plaintiffs when they felt there was "an abnormal amount of traffic" coming through the hotel parking lot to visit their room. The plaintiffs further allege, on information and belief, that staff used their monitoring of the plaintiffs to charge them more for extending their reservations after days when the plaintiffs had gotten more business. At the Lexington Inn & Suites in Elgin, the complaint says Emily once told front-desk staff she had to wait to pay for the room because she "had an appointment," and staff held the room until she finished with the client.
Judge Hunt rejected the hotels' argument that each alleged red flag had an innocent alternative explanation, writing that Litchfield "improperly considers these details in a vacuum" and that when viewed as a whole, the allegations make the perpetrator-liability claim plausible. On the knowledge standard, the court quoted a recent district court decision for the proposition that courts routinely find that when hotel staff observe red flags — including cash payments, extended stays, foot traffic, and young women on the property — and then continue to rent hotel rooms to traffickers, the plaintiff has done enough to survive a motion to dismiss on a harboring claim.
The ruling drew a sharp line at two Marriott-branded properties. Judge Hunt dismissed all claims against Marriott Hotel Services, which operated the Chicago Marriott Downers Grove, finding the complaint's allegations too conclusory — a sympathetic employee who greeted the women and once asked if Emily was okay did not, without more, plausibly establish that Marriott staff knew the women were trafficking victims. Claims tied to the Courtyard by Marriott Chicago Elgin-West Dundee were similarly dismissed, the court finding those allegations thin and conclusory.
The franchisors — Choice Hotels, Super 8 Worldwide, and ESH Strategies Franchise — survived on indirect theories only. Judge Hunt rejected the plaintiffs' direct beneficiary claims, finding no allegations that Block had a continuous business relationship with any franchisor rather than with the individual hotel operators. The court allowed vicarious-liability and joint-employer theories to proceed against Choice Hotels and Super 8 Worldwide, crediting allegations that the franchisors controlled hiring, set room rates and employee compensation, mandated staff training, and retained the right to detect criminal activity through their proprietary computer systems. ESH Strategies, which franchised the Extended Stay, was held to have conceded the indirect-liability point by failing to address it in briefing.
The Illinois Trafficking Victims Protection Act claim against ESA P and ESH — based on allegations that the Extended Stay knowingly charged the plaintiffs higher rates on days when they had more clients — also survived, with Judge Hunt rejecting the argument that the statute required Block to have physically handed money to the front desk himself.
Defendants must answer the surviving claims by May 29, 2026, and the parties must submit a joint proposed discovery plan by June 5, 2026.