A federal court in Florida granted in part and denied in part a motion to dismiss brought by the parent company of the franchisor of the Days Inn brand. The complaint alleged violations of the Trafficking Victims Protection Reauthorization Act (TVPRA) and related state-law claims arising from the alleged sex trafficking of the plaintiff at a Days Inn franchised hotel in 2017. Weiner v. Wyndham Hotels and Resorts, Inc., 2026 WL 120224 (M.D. Fla. Jan. 16, 2026).
Weiner claimed Wyndham benefited from and participated in a trafficking venture through its receipt of franchise fees, brand-level control over the hotel, and requirement that branded hotels strictly conform to the franchise agreement. She further claimed that Wyndham failed to require, verify, or enforce the franchised hotel’s compliance with Wyndham’s anti-trafficking training requirements. Wyndham moved to dismiss all claims. The court dismissed Weiner’s beneficiary liability TVPRA claim, finding that she failed to sufficiently plead (1) a common undertaking that could give rise to the inference that Wyndham helped facilitate the human trafficking; (2) Wyndham’s participation in a sex trafficking venture beyond participation in shared revenue as part of its normal role as franchisor; and (3) that Wyndham had actual or constructive knowledge of the alleged TVPRA violation. The court also dismissed Weiner’s state law negligence claim as time‑barred because Florida’s four‑year statute of limitations—not the TVPRA’s ten-year limitations period—applied. The court, however, allowed Weiner’s separate vicarious liability claim to proceed.
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