New Jersey federal court denied a Super 8 franchisee’s motion to dismiss, holding that venue in the District of New Jersey was proper and that the plaintiff’s Trafficking Victims Protection Reauthorization Act (TVPRA) claims were timely. Doe v. Wyndham Hotels & Resorts, Inc., 2025 WL 3754148 (D.N.J. Dec. 24, 2025).
Plaintiff Doe sued Shailey Enterprises, L.C., the owner of a franchised Super 8 Motel and Wyndham, the franchisor of the Super 8 brand. Doe alleged she was trafficked at Shailey’s franchised motel in Norfolk, Virginia, between February 2014 and February 2015. Doe alleged that Shailey and Wyndham were subject to direct beneficiary liability under the TVPRA for the trafficking, and that Wyndham was liable under vicarious liability theories as well.
Shailey moved to dismiss, arguing that Doe’s claims were time-barred since the trafficking occurred in 2014. Shailey further argued that venue was improper because the trafficking occurred in Virginia. The court rejected these arguments, finding that the amended complaint alleged continuous trafficking through February 2015, making the February 2025 filing timely under the TVPRA’s 10-year statute of limitations. The court also held that venue was proper in New Jersey because a substantial part of the events giving rise to the claims occurred there. Specifically, Wyndham’s corporate headquarters were located in New Jersey, and Wyndham allegedly controlled policies, training, and reporting requirements related to trafficking and profited from Shailey’s operations. The court emphasized that the claims focus on corporate decision-making and systemic failures at the franchisor level, rather than isolated acts at the hotel or franchisee level. Accordingly, the court permitted Doe’s claims to proceed in New Jersey.
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