Three minor females were sex trafficked at two Georgia hotels — A.G. and G.W. at United Inn operated by Northbrook Industries Inc., and C.B. at Hilltop Inn operated by Naseeb Investments Inc. The traffickers used United Inn repeatedly, with front desk staff speaking to them for 15-20 minutes daily and allowing the locked-out victims back into rooms without identification. At Hilltop Inn, registered sex offender Timothy Chappell rented a second room nightly for trafficking C.B., with staff following his instructions not to clean it.
Judge Anne Conway wrote that "something more than engaging in an ordinary buyer-seller transaction is required" to establish participation in a venture under the Trafficking Victims Protection Reauthorization Act. The court found sufficient evidence that both hotels offered "personalized support" to the trafficking operations, distinguishing these facts from mere arms-length room rentals. "A jury certainly could find it significant that United Inn allowed A.G. and G.W., two seventeen-year-old girls dressed provocatively who were loitering in common areas and purchasing condoms in the lobby, back into a room even though they produced no identification," Conway noted.
Both district courts had granted summary judgment for the hotel operators, finding insufficient evidence of participation in ventures. A.G. and G.W. had also brought negligence claims under Georgia law, with the district court ruling they were licensees rather than invitees because they were at the hotel for unlawful purposes.
The decision provides clarity on TVPRA beneficiary claims while creating a circuit split on the "participation in a venture" standard. The ruling allows trafficking victims to pursue civil damages against businesses that provide more than routine services to traffickers, potentially affecting how hotels and other businesses handle suspected trafficking situations.