Two recent eight-figure jury verdicts against business owners in Dekalb County should not be taken lightly or ignored. In both instances, the juries found the business owners, one a motel owner, and the other a salon/spa owner, knew or reasonably should have known of illegal activities taking place on their premises.
Sex Trafficking
In the first case, a jury in the United States District Court for the Northern District of Georgia, Atlanta Division, awarded a sex trafficking victim $40 million dollars. The verdict consisted of $10 million dollars in compensatory damages and $30 million dollars in punitive damages.[i] The victim, age 16 at the time, was allegedly trafficked over 200 times at the United Inn and Suites, located on Memorial Drive in Decatur, Georgia.[ii]
At trial, the hotel claimed staff did not know trafficking was taking place. [iii] Plaintiff successfully argued if United Inn and Suites did not know of the trafficking activity, they should have known, citing various laws, codes, and policies.[iv] The lack of knowledge defense was not successful.
Know the Law, Know the Rules, Know the Standards
Businesses prone to being exposed to human trafficking such has hotels, airports, bus stations and other hospitality businesses, should know the law and safety standards associated with running those businesses.
First, the Trafficking Victims Protection Authorization Act (“TVPRA”)—18 U.S.C. §1595(a)—states: “An individual who is a victim of a violation of this chapter may bring a civil action against the perpetrator (or whoever knowingly benefits, or attempts or conspires to benefit, financially or by receiving anything of value from participation in a venture which that person knew or should have known has engaged in an act in violation of this chapter) in an appropriate district court of the United States and may recover damages and reasonable attorneys fees.”[v]
According to news reports, plaintiff’s attorney in the United Inn case argued “the staff knew what was happening to his client, and refused to step in. He said the hotel even profited from the crime taking place there”.[vi]
Second, Georgia has its own specific trafficking laws, including GA Code § 16-5-47. It requires specified businesses to post a model notice available from the Georgia Bureau of Investigation to enable persons subjected to human trafficking to obtain help and services.[vii] The Georgia Legislature has expressly applied this law to hotels since September 15, 2013.[viii]
Many organizations provide notices and publications for business owners, which include training to protect victims of human trafficking. In 2010, the Department of Homeland Security (“DHS”), started a national public awareness campaign called the Blue Campaign and Human Trafficking Response Guide for the Hospitality Industry to encourage awareness and training.[ix]
Because hotel owners and other hospitality businesses can be held accountable, they must educate their staff as to human trafficking signs, such as:
- People appearing to be deprived of food, water, sleep, basic hygiene, medical care, or other necessities?
- People acting fearful, anxious, depressed, submissive, tense, nervous/paranoid, or disassociated/“checked out”?
- Bruises or other signs of physical trauma?
- Tattoos or scars indicating branding by a trafficker?
- Scars, cut marks, burns, or other signs of self-harm/suicidal tendencies?
- People deferring to another person to speak for them?[x]
Unlicensed and Sexual Assault
In the second case, two plaintiffs filed suit in Dekalb County State Court against Ponce Feet Spa. The jury awarded the two plaintiffs $13 million dollars because they were sexually assaulted by an unlicensed massage therapist.
Each woman received compensatory damages from both the spa and its owner, as well as $2 million dollars in punitive damages to deter future misconduct.[xi]
One of the plaintiffs’ attorneys, Mawuli Davis said, “The spa had hired an unlicensed and untrained man to perform massages, resulting in assaults that caused mental anguish.[xii] “The plaintiffs sued the spa and its owner for negligence in hiring, retention and under a theory of respondent superior.”[xiii]
Unlike the United Inn Defendants, it appeared Ponce Feet Spa had knowledge, but just like the United Inn, the business owners chose profit over people and safety.
Takeaways: Ignorance of The Law Is No Excuse and Neither Is Cost
- Research business laws for your business, including licensing laws, safety standards and other code and regulation requirements.
- Maintain policies and procedures requiring written reporting of actual or potential criminal activities. IF YOU SEE SOMETHING, SAY SOMETHING!
- Conduct criminal background investigations of all potential employees.
- Have policies that require investigating the premises, especially when BOLO (be on the lookout) and other kidnap notices are received.
- Maintain proper security, especially when instances of crime have taken place, or have been reported.
- Properly train staff and employees on sex trafficking and other criminal activities, and on what to look out for.
At the end of the day, a defendant cannot merely argue a lack of knowledge when the evidence suggests the defendant reasonably should have known. Do your investigations, conduct proper trainings, and paper your files.
Sources
[i] Decatur hotel ordered to pay $40M for ignoring child sex trafficking, August 27, 2025, https://www.fox5atlanta.com/news/decatur-hotel-must-pay-40m-ignoring-child-sex-trafficking
[ii] Ibid.
[iii] Ibid
>[iv] Complaint for Damages, ¶¶ 2,53,55,57,58,60,63, Case No. 1:20-cv-05233-SEG, Doc 1, Filed December 28,2020.
[v] 18 U.S.C. § 1595(a); emphasis added.
[vi] Decatur hotel ordered to pay $40M for ignoring child sex trafficking, August 27, 2025, https://www.fox5atlanta.com/news/decatur-hotel-must-pay-40m-ignoring-child-sex-trafficking
[vii] GA Code § 16-5-47
>[viii] GA Code § 16-5-47(b)(12)
>[ix] Fact Sheet: Combating Human Trafficking at DHS, August 27, 2025, https://www.dhs.gov/archive/news/2016/10/24/fact-sheet-combating-human-trafficking-dhs
>[x] For a more extensive list see: https://www.dhs.gov/blue-campaign/publication/blue-campaign-toolkits-and-guides
>[xi] DeKalb Jury Returns $13M Verdict After Women Assaulted at Spa, August 27, 2025, https://www.law.com/dailyreportonline/2025/07/14/dekalb-jury-returns-13m-verdict-after-women-assaulted-at-spa/?slreturn=20250825120653
>[xii] Ibid.
>[xiii] Ibid.
