Imagine a guest checking in, alone, for what appears to be a routine overnight stay. Behind the closed door, however, criminal activity is happening — a victim of human trafficking is trapped, and the trafficker is profiting off their exploitation.

For decades, hotels were considered neutral ground — a space where they provided rooms and services but bore little responsibility for what happened behind closed doors. That is no longer the case. Across the country, survivors are holding hotels accountable under civil laws, including the federal Trafficking Victims Protection Reauthorization Act (TVPRA).

The TVPRA doesn’t just target traffickers. It allows victims to pursue damages from any individual or business that knowingly benefits from trafficking, or should have known about it. In practice, that means revenue from room rentals, long-term stays, or other hotel services can trigger liability. Recent amendments have removed statutes of limitations for minors, keeping the door open indefinitely for claims.

When Lawsuits Tell the Story

The legal landscape is no longer hypothetical — it’s very real. Hotels are facing lawsuits with staggering financial stakes: 

• In Georgia, a federal jury awarded $40 million to a teenage survivor who was trafficked in a hotel room while staff ignored obvious warning signs like heavy foot traffic and law enforcement alerts.

• Multi-million-dollar settlements have followed, sending a clear message: failure to act can be costly.

• In Oakland, California, plaintiffs are suing a hotel near the airport, claiming it “knew or should have known” trafficking was occurring on its property.

• Pennsylvania law firms are pursuing franchise-wide claims, alleging corporate oversight allowed trafficking to persist, potentially implicating even national brands.

  
  

These cases underscore a hard truth: courts and regulators are increasingly willing to hold hotels accountable, not just the traffickers.

Local Legislation Raises the Stakes

States and municipalities are also stepping up. In Suffolk County, New York, a law targeting hotels now requires:

• Extended retention of guest records

• Mandatory anti-trafficking training for all staff

• Minimum six-hour booking restrictions to prevent exploitative hourly room rentals

• Easier access for law enforcement to digital records

Laws like this illustrate a broader trend: governments are expecting hotels to be proactive in detecting and deterring trafficking, not just reactive.

The Challenges Hotels Face

Red flags are often subtle, and staff are unprepared:

• Limited training leaves employees unsure how to act

• Documentation and escalation protocols may be inconsistent

• Digital recordkeeping is often incomplete

• Suspicious patterns — repeated bookings, cash payments, visible signs of abuse — can go unnoticed
  
  

Civil claims often hinge on whether the hotel “knew or should have known.” In other words, inaction itself can be evidence of negligence.

Turning Risk into Action

Despite the challenges, hotels have options to protect guests and themselves:

• Invest in robust training: Employees need clear guidance on recognizing red flags and reporting suspicious activity.

• Establish clear protocols: Every staff member should know how to escalate concerns to management and law enforcement.

• Strengthen recordkeeping: Digital, auditable records can deter traffickers and provide evidence of due diligence.

• Conduct internal investigations: When red flags appear, structured investigations can identify risks and demonstrate good faith before lawsuits arise.

• Invest in new technology: Tools like Dark Watch Scans help hotels proactively detect suspicious activity, identify trafficking patterns, and provide actionable intelligence — giving staff a real advantage in protecting guests and mitigating liability.
  
  

By combining trained staff, clear protocols, and intelligent technology, hotels can turn legal exposure into operational strength.

The Bottom Line

For hotel leaders, the stakes are clear: the era of plausible deniability is over. Human trafficking is not just a social problem — it’s a legal and financial risk. Lawsuits, settlements, and new legislation make one thing unmistakably clear: doing nothing is no longer an option.

The choice is strategic: embrace anti-trafficking programs now, train your staff, implement clear policies, and leverage technology like Dark Watch — or face the growing wave of civil liability that will inevitably find those who turn a blind eye.