A Florida federal district court recently granted summary judgment, holding that claims under the Trafficking Victims Protection Reauthorization Act (TVPRA) were time-barred. Doe K.R. v. Choice Hotels, 2025 WL 3469855 (M.D. Fla. Dec. 3, 2025).
Plaintiff Doe brought TVPRA claims against WGH SU Delegates, LLC, the franchisee and operator of a franchised hotel, and the franchisor, Choice Hotels International, Inc., and its related entity (together, “Choice Hotels”). Doe alleged that at age 18 she was trafficked at Delegates’ hotel in Orlando, Florida, for a period of 12 weeks between March and May 2013. As in similar TVPRA actions, Doe alleged that Delegates and Choice Hotels violated the TVPRA because they allegedly formed a “hotel franchising venture” and knew or should have known that the venture facilitated TVPRA violations. Doe also alleged that Delegates and Choice Hotels formed a commercial venture with her trafficker in exchange for a share of profits earned on the rental of rooms used for sex trafficking.
On summary judgment, the court entered judgment for Delegates and Choice Hotels because Doe’s claims were untimely. As Doe was 18 at the time of the alleged trafficking, her TVPRA claims were subject to a 10-year statute of limitations pursuant to 18 U.S.C. § 1595(c)(1). It was undisputed that Doe did not commence her action until 10 years and five days after her alleged sex trafficking at the hotel ceased. The court rejected the Doe’s claims that the limitations period should be equitably tolled or that the delayed discovery doctrine should apply. Because Doe did not explain what steps she took to diligently investigate her claims, nor explain why she waited so long to file, she did not demonstrate the diligence required for equitable tolling. The court noted that she first met with her attorneys several years before filing suit, undercutting any claim of diligence.
Additionally, because Doe did not allege that the defendants withheld evidence, intimidated witnesses, or otherwise frustrated her attempts to file suit, she did not meet the extraordinary circumstances requirement for equitable tolling. The court expressed doubt that the delayed discovery doctrine applied to Doe’s TVPRA claims. In any event, the relevant consideration under that doctrine was whether she knew the facts of her injury, not whether she understood she had a cause of action. Doe had knowledge of the facts supporting her claim upon her departure from the hotel in May 2013; thus, the delayed discovery doctrine did not apply. Because the claims were untimely, the court declined to address the substance of the claims, including validity of the hotel franchising venture theory.