P.C. v. D Fort Hotel, LLC.

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Chief Judge Philip A. Brimmer
Civil Action No. 24-cv-01584-PAB-TPO
P.C.,
Plaintiff,
v.
D FORT HOTEL, LLC.,
Defendant.
ORDER
The matters before the Court are the Motion to Dismiss [Docket No. 11], filed by
defendant D Fort Hotel, LLC., and Plaintiff’s Motion to Proceed Under Pseudonym for
Pretrial Proceedings [Docket No. 22]. The Court has jurisdiction pursuant to 28 U.S.C.
§ 1331.
I. 	BACKGROUND 1
A. Factual Background
Defendant D Fort Hotel, LLC. (“D Fort”), is the owner and operator of a hotel
known as Motel 6 Fort Collins (the “Motel 6”) located in Fort Collins, Colorado. Docket
No. 1 at 1, ¶ 2. Plaintiff P.C. 2 was sex trafficked at the Motel 6 in 2022. Id. at 2, ¶ 9.
P.C.’s sex trafficker deliberately and repeatedly selected the subject hotel as a venue
1 The facts below are taken from plaintiff’s complaint, Docket No. 1, and are
presumed to be true, unless otherwise noted, for purposes of ruling on the motion to
dismiss.
2 For the reasons discussed below, the Court will grant plaintiff’s request to
proceed using her initials and will refer to her as P.C.
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for sex trafficking in 2022, and sex trafficking had occurred at the Motel 6 prior to 2022.
Id. at 2, 4, ¶¶ 10, 18. While P.C. was being trafficked at the Motel 6, her trafficker had
direct interaction with hotel staff by paying staff members to act as lookouts and to
inform her trafficker of police activity. Id. at 6–7, ¶ 37. D Fort’s staff witnessed frequent
signs of sex trafficking, including: (a) constant foot traffic of sex buyers to the rooms
rented by the trafficker to have sex with victims; (b) trafficked victims, who were bruised,
malnourished, drug and alcohol-impaired, sleep-impaired, hygiene-impaired, and
behavior-impaired, walking around the hotel in sexually explicit clothing; (c) suspicious
individuals loitering outside the hotel rooms when a sex buyer would enter a room; (d)
suspicious items that were observed by housekeeping staff inside the hotel rooms
rented by the trafficker, including weapons, cash, drugs, drug paraphernalia, condoms,
and lubricants; (e) traffickers monitoring hotel hallways and doors or walking the hotel’s
perimeter; and (f) P.C. soliciting for sex buyer business in common areas. Id. at 7–8,
¶¶ 45–46. During 2022, P.C. interacted with hotel staff on a daily basis, and staff
witnessed and observed P.C., her trafficker, and a steady procession of sex buyers
going in and out of the rooms rented to the trafficker. Id. at 8, ¶ 48.
The Motel 6 could deny accommodation to a guest or eject a guest for (1) being
visibly under the influence of drugs or alcohol; (2) creating a nuisance to the public; (3)
using a hotel room for unlawful purposes; (4) using hotel amenities and premises for
unlawful acts; (5) bringing in unregistered guests; (6) disturbing other guests; and (7)
violating other rules set by the hotel. Id. at 9, ¶ 50.
D Fort was on notice of the high likelihood of illegal sex trafficking occurring at
the Motel 6 through the passage of the Trafficking Victims Protections Reauthorization
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Act (“TVPRA”) in 2008 and numerous other legislative initiatives. Id. at 3, ¶ 12. As a
hotel operator, D Fort controlled the training, policies, and decisions on the
implementation and execution of anti-trafficking policies, protocols, rules, and guidelines
for the Motel 6. Id. at 2–3, ¶ 11. D Fort failed to implement sufficient educational and
training programs on sex trafficking within its business chain of command, as well as
failed to implement policies for preventing, identifying, reporting, documenting,
investigating, and stopping sex trafficking at the Motel 6. Id. at 3, ¶ 14.
B. Procedural Background
On June 6, 2024, plaintiff filed her complaint, identifying herself only by the
initials P.C. Id. at 1. P.C. brings two claims against D Fort, namely, one claim of
violating the TVPRA, 18 U.S.C § 1595(a), for knowingly benefitting from participation in
a venture which D Fort knew or should have known was engaged in sex trafficking, and
one claim of negligence. Id. at 5–17, ¶¶ 25–86. On August 8, 2024, D Fort filed its
motion to dismiss, arguing that P.C. has failed to plausibly allege her federal TVPRA
claim and that the Court should therefore dismiss both claims because the Court lacks
jurisdiction over her state law negligence claim. Docket No. 11 at 1–2. P.C. responded,
Docket No. 12, and D Fort replied. Docket No. 13.
On September 14, 2024, the Court ordered plaintiff to file a motion to proceed
under her initials, as opposed to her true name, noting that, “[a]lthough the complaint
incorporates a rationale for the plaintiff to be able to identify herself solely by her initials,
the proper procedure is, upon filing the complaint, to contemporaneously file a motion to
proceed by use of initials.” Docket No. 18. P.C. filed the motion to proceed under her
initials on September 18, 2024. Docket No. 22. D Fort did not respond.
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II. 	LEGAL STANDARD
A. Motion to Dismiss
To survive a motion to dismiss under Rule 12(b)(6) of the Federal Rules of Civil
Procedure, a complaint must allege enough factual matter that, taken as true, makes
the plaintiff’s “claim to relief . . . plausible on its face.” Khalik v. United Air Lines, 671
F.3d 1188, 1190 (10th Cir. 2012) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570
(2007)). “The ‘plausibility’ standard requires that relief must plausibly follow from the
facts alleged, not that the facts themselves be plausible.” RE/MAX, LLC v. Quicken
Loans Inc., 295 F. Supp. 3d 1163, 1168 (D. Colo. 2018) (citing Bryson v. Gonzales, 534
F.3d 1282, 1286 (10th Cir. 2008)). Generally, “[s]pecific facts are not necessary; the
statement need only ‘give the defendant fair notice of what the claim is and the grounds
upon which it rests.’” Erickson v. Pardus, 551 U.S. 89, 93 (2007) (per curiam) (quoting
Twombly, 550 U.S. at 555) (alterations omitted). A court, however, does not need to
accept conclusory allegations. See, e.g., Hackford v. Babbit, 14 F.3d 1457, 1465 (10th
Cir. 1994) (“[W]e are not bound by conclusory allegations, unwarranted inferences, or
legal conclusions.”).
“[W]here the well-pleaded facts do not permit the court to infer more than the
mere possibility of misconduct, the complaint has alleged – but it has not shown – that
the pleader is entitled to relief.” Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009) (quotations
and alterations omitted); see also Khalik, 671 F.3d at 1190 (“A plaintiff must nudge [his]
claims across the line from conceivable to plausible in order to survive a motion to
dismiss.” (quoting Twombly, 550 U.S. at 570)). If a complaint’s allegations are “so
general that they encompass a wide swath of conduct, much of it innocent,” then
plaintiff has not stated a plausible claim. Khalik, 671 F.3d at 1191 (quotations omitted).
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Thus, even though modern rules of pleading are somewhat forgiving, “a complaint still
must contain either direct or inferential allegations respecting all the material elements
necessary to sustain a recovery under some viable legal theory.” Bryson, 534 F.3d at
1286 (alterations omitted).
B. The Trafficking Victims Protection Reauthorization Act
Congress enacted the Trafficking Victims Protection Act in 2000, creating
criminal offenses for forced labor and sex trafficking. Pub. L. No. 106-386, 114 Stat.
1464 (2000). The original act did not contain a private right of action. Griffin v. Alamo,
2016 WL 7391046, at *2 (W.D. Ark. Dec. 21, 2016). However, in 2003, Congress
added a right of action for victims to sue their traffickers civilly. Pub. L. No. 108-193,
117 Stat. 2875 (2003). In 2008, Congress further amended the law to permit victims to
sue those who facilitate trafficking ventures. The 2008 law provides
An individual who is a victim of a violation of this chapter may bring a civil action
against the perpetrator (or whoever knowingly benefits, 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.
18 U.S.C. § 1595(a) (emphasis added).
To state a claim under a § 1595(a) beneficiary theory, a plaintiff must allege facts
from which it can be reasonably inferred that a defendant (1) “knowingly benefit[ted]
financially or by receiving anything of value” (2) from participation in a venture that
defendant “knew or should have known has engaged in” sex trafficking. 18 U.S.C.
§ 1595(a); A.B. v. Marriott Int’l, Inc., 455 F. Supp. 3d 171, 181 (E.D. Pa. 2020). Sex
trafficking includes the use “of force, threats of force, fraud, coercion . . . , or any
combination of such means” “to cause [a] person to engage in a commercial sex act.”
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18 U.S.C. § 1591(a). The act defines “coercion” as “threats of serious harm to or
physical restraint against any person” or “any scheme, plan, or pattern intended to
cause a person to believe that failure to perform an act would result in serious harm to
or physical restraint against any person.” Id., § 1591(e)(2)(A)–(B).
A plaintiff may satisfy these elements in one of two ways. She may show that the
defendant’s own acts, omissions, and state of mind establish each element.
Alternatively, she may impute to the defendant the acts, omissions, and state of mind of
an agent of the defendant. The former is referred to as “direct liability” and the latter as
“indirect liability.” See, e.g., A.B. v. Hilton Worldwide Holdings, Inc., 2020 WL 5371459,
at *6 (D. Ore. Sept. 8, 2020); B.M. v. Wyndham Hotels & Resorts, Inc., 2020 WL
4368214, at *4 (N.D. Cal. July 30, 2020).
C. Motion to Proceed Under Initials
“Proceeding under pseudonym in federal court is, by all accounts, an unusual
procedure.” Femedeer v. Haun, 227 F.3d 1244, 1246 (10th Cir. 2000) (quotation
omitted). “Moreover, there does not appear to be any specific statute or rule supporting
the practice. . . . To the contrary, the Federal Rules of Civil Procedure mandate that all
pleadings contain the name of the parties, see Fed. R. Civ. P. 10(a), and Rule 17(a)
specifically states that ‘[e]very action shall be prosecuted in the name of the real party in
interest.’” Id. (quoting Fed. R. Civ. P. 17(a)). However, the Tenth Circuit has
recognized three “exceptional” circumstances permitting a party to proceed under a
pseudonym: (1) “cases involving matters of a highly sensitive and personal nature,” (2)
cases involving a “real danger of physical harm,” and (3) “where the injury litigated
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against would be incurred as a result of the disclosure of the plaintiff’s identity.” 3 Id.
(quoting Doe v. Frank, 951 F.2d 320, 324 (11th Cir. 1992)).
“The public has a common law right to access judicial records and documents in
civil cases, but the right is not absolute.” Doe v. FBI, 218 F.R.D. 256, 258 (D. Colo.
2003). “[I]t is proper to weigh the public interest in determining whether some form of
anonymity is warranted.” Femedeer, 227 at 1246. “Ordinarily, those using the courts
must be prepared to accept the public scrutiny that is an inherent part of public trials.”
Id. “The risk that a plaintiff may suffer some embarrassment is not enough” to permit
the plaintiff to proceed anonymously. Id.
III. 	ANALYSIS
A. Motion to Proceed Under Initials
P.C. seeks leave to identify herself using only her initials during the pretrial
proceedings in this case. Docket No. 22 at 1. She argues that the highly personal and
intimate nature of the allegations in the complaint weighs in favor of permitting her to
use her initials. Id. at 3. Moreover, P.C. asserts that allowing this degree of anonymity
in a case involving allegations of sex trafficking serves the public interest because
failing to do so would chill other victims of sex trafficking from litigating their claims. Id.
at 5.
Courts have found that cases involving claims of sex trafficking warrant allowing
plaintiffs to proceed under their initials because plaintiffs litigating such claims “will be
called upon to disclose alleged experiences which are sensitive, highly personal in
3 These exceptional circumstances apply equally in considering whether a
plaintiff may proceed under her initials rather than under a pseudonym. See, e.g., S.Y.
v. Choice Hotels Int’l, Inc., 2021 WL 4167677, at *1 (M.D. Fla. Sept. 14, 2021)
(permitting plaintiffs to proceed using initials S.Y. and C.S.).
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nature, and involve the utmost intimacy.” S.Y., 2021 WL 4167677, at *2; see also A.B.
v. Shilo Inn, Salem, LLC, 2023 WL 5237714, at *3 (D. Or. Aug. 15, 2023) (“Because this
Court finds the need for anonymity outweighs any prejudice to the Defendants and the
public, this Court grants leave for Plaintiff to proceed under the pseudonym ‘A.B.’ in this
case.”); B.J. v. G6 Hosp., LLC, 2023 WL 3569979, at *1 (N.D. Cal. May 19, 2023); J.C.
v. Choice Hotels Int’l, Inc., 2020 WL 3035794, at *1 (N.D. Cal. June 5, 2020); J.M. v.
Choice Hotels Int’l, Inc., 2022 WL 10626493, at *3 (E.D. Cal. Oct. 18, 2022).
The Court finds that requiring plaintiff to proceed under her full name would result
in more than “[t]he risk that a plaintiff may suffer some embarrassment,” Raiser v.
Brigham Young Univ., 127 F. App’x 409, 411 (10th Cir. 2005) (unpublished), and that
the scope of her claims raises more than economic or professional concerns. Nat’l
Commodity and Barter Ass’n v. Gibbs, 886 F.2d 1240, 1245 (10th Cir. 1989) (leave to
proceed under a pseudonym will not be granted “when only the plaintiff’s economic or
professional concerns are involved”). Rather, the Court agrees with the reasoning of
other courts that plaintiffs’ sex trafficking claims are of a “highly sensitive and personal
nature.” Femedeer, 227 at 1246. Here, P.C. alleges that she was repeatedly victimized
and trafficked for sex, that she was psychologically and physically prohibited from
escaping, and that the trauma of her being trafficked has led to depression, anxiety
disorders, and PTSD. Docket No. 1 at 2–4, 9, ¶¶ 6, 17, 51. The public interest in
access to judicial records is outweighed by P.C.’s privacy interests in this case, and the
Court will grant plaintiff’s motion to use her initials in the pretrial phase of this case.
B. Motion to Dismiss
D Fort argues that P.C. has failed to adequately plead a TVPRA violation
because, while the allegations in the complaint may plausibly allege that D Fort was
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aware that commercial sex occurred at the Motel 6, there are no allegations that show D
Fort knew that P.C.’s participation was not voluntary, i.e. that she was being trafficked.
Docket No. 11 at 4–5, ¶ 4. D Fort states that, “[a]lthough Plaintiff alleged indicia of
commercial sex activity, when the victim is an adult, § 1591 only provides a remedy for
commercial sex activity involving ‘force, threats of force, fraud, [or] coercion’” and that
“[i]t is the force or coercion element that is absent from the Complaint.” Id. (quoting 18
U.S.C. § 1591(a)). It contends that “[t]he Complaint did not allege that any of D Fort’s
personnel witnessed non-consensual sex activity (or, indeed, any sex activity at all) or
witnessed Plaintiff being threatened or assaulted by her alleged trafficker,” and that
such allegations are necessary to support her TVPRA claim. Id.
P.C. responds that the allegations in the complaint, taken as true, show that D
Fort should have known that sex trafficking was taking place at the Motel 6. 4 Docket
No. 12 at 11. She claims that the allegations contain sufficient red flags that are alleged
to have been seen by hotel staff to put them on notice of the non-consensual nature of
the sex work, including (1) weapons, drugs, and lubricants in rooms rented by her
trafficker; (2) P.C.’s signs of abuse, such as bruises and her malnourished state; and (3)
the “constant foot traffic of sex buyers to the trafficker rented rooms to have sex with
trafficked victims.” Id. at 12 (quoting Docket No. 1 at 7–8, ¶ 45). She asserts that
courts have found similar allegations regarding signs of violence and abuse sufficient to
4 Plaintiff’s response also argues that she has plausibly alleged that (1) she is a
victim of sex trafficking, (2) D Fort participated in the sex trafficking venture, and (3) D
Fort knowingly benefited from its participation in the venture. Docket No. 12 at 4–10.
Because D Fort challenges only the sufficiency of the complaint as to whether D Fort
knew that the commercial sex allegedly occurring at the Motel 6 was not voluntary, it is
unnecessary to consider P.C.’s arguments on these other issues.
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plausibly allege that defendants should have known that they were participating in a
venture that violated the TVPRA. Id. at 13 (citing J.G. v. Northbrook Indus., Inc., 619 F.
Supp. 3d 1228, 1238 (N.D. Ga. 2022); Doe 4 v. Red Roof Inns, Inc., 2021 WL
12104819, at *7 (N.D. Ga. Feb. 3, 2021)).
D Fort is correct that many of the allegations in P.C.’s complaint support only the
proposition that P.C. and her trafficker were engaged in commercial sex work, but not
that P.C. was being trafficked. For example, while P.C.’s allegations that hotel staff
observed “weapons, cash, drugs, drug paraphernalia, condoms, [and] lubricants” or that
they observed P.C. in sexually explicit clothing “soliciting for sex buyer business in
common areas” is indicative of commercial sex work, as well as other illegal activity,
these allegations do not support the inference that P.C. was engaging in this activity
due to force, threats of force, fraud, or coercion. Docket No. 1 at 7–8, ¶ 45. Moreover,
while courts have relied on allegations similar to those in P.C.’s complaint to find that
the plaintiff had plausibly alleged a TVPRA claim, these courts have also relied on
allegations that provide more direct evidence of force and coercion. See, e.g., J.G., 619
F. Supp. 3d at 1238–39 (finding that defendant should have known about sex trafficking
based on plaintiff’s allegations that she had visible signs of physical injuries and poor
hygiene, that plaintiff’s traffickers carried weapons and operated openly, and that hotel
staff saw condoms, drugs, weapons, and many towels, sheets, and tissues in plaintiff’s
room, but also relying on the fact that plaintiff looked underage and was wearing
inappropriate clothing); S.Y. v. Naples Hotel Co., 476 F. Supp. 3d 1251, 1257 (M.D. Fla.
2020) (finding that defendant should have known about sex trafficking based on
allegations that plaintiff’s hotel room contained excessive used condoms and traffickers
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made excessive requests for towels and linens in the rooms, but also relying on pleas
and screams for help coming for victim’s rooms); M.A. v. Wyndham Hotels & Resorts,
Inc., 425 F. Supp. 3d 959, 967 (S.D. Ohio 2019) (finding that defendant should have
known about sex trafficking based on allegations that hotel staff saw trash cans
containing an extraordinary number of used condoms, but also that hotel staff ignored
plaintiff’s pleas for help).
The Court, however, finds that three of plaintiffs’ allegations support an inference
that D Fort staff should have known that P.C. was being trafficked, namely, P.C.’s
allegations that (1) bruised, malnourished, drug and alcohol-impaired, sleep-impaired,
and hygiene-impaired trafficking victims would walk around hotel grounds, (2) that D
Fort staff witnessed P.C., her trafficker, and a steady procession of sex buyers going in
and out of a single room on a daily basis, and (3) that P.C.’s trafficker had direct
interaction with hotel employees by paying them to serve as lookouts/informants.
Docket No. 1 at 7–8, 14, ¶¶ 45,48, 72.
Courts have found that allegations of injuries, such as bruises, support an
inference that hotel staff should have known that the commercial sex activity was also
part of a human trafficking operation. See, e.g., A.B. v. Marriott Int’l, Inc., 455 F. Supp.
3d 171, 178 (E.D. Pa. 2020) (“A.B. alleges Marriott knew or should have known about
A.B.’s trafficking” in part because of “prominent bruising and injury on her body.”); Doe
S.W. v. Lorain-Elyria Motel, Inc., 2020 WL 1244192, at *5 (S.D. Ohio Mar. 16, 2020)
(relying on the allegations that defendants ignored “obvious signs of human trafficking
(bruises and physical deterioration) and indicators of commercial sex activity (bottles of
lubricants, boxes of condoms, excessive requests for towels and linens, cash
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payments)”); M.A., 425 F. Supp. 3d at 962, 968 (“She also alleges facts specific to her
own sex trafficking, including a number of signs she alleges should have alerted staff to
her situation,” such as that “the hotel staff would have or should have observed visible
physical changes, such as bruising. . . . These allegations are sufficient to survive a
12(b)(6) motion to dismiss.”); J.G., 619 F. Supp. 3d at 1236.
Courts have also found that allegations of voluminous sex buyers are indicative
of the fact that the commercial sex activity was coerced. See, e.g., A.G., 2022 WL
1644921, at *4 (finding that “the amount of men visiting [plaintiff’s] room, [and] the
disturbances caused by the men visiting Plaintiff’s room” demonstrate that defendant
had constructive knowledge that plaintiff was being sex trafficked); S.Y., 476 F. Supp.
3d at 1257 (finding plaintiff had plausibly alleged a TVPRA violation, in part, because
she alleged there were “[m]ultiple men per day coming and going from the same rooms
without luggage or personal possessions”); A.B., 455 F. Supp. 3d at 193 (finding plaintiff
had plausibly alleged a TVPRA violation, in part, because she alleged that “as many as
six men an evening entered each of the three hotels as an ‘unannounced guest,’
creating a ‘voluminous and obvious’ constant stream of male visitors to A.B.’s rooms
accessed through the front door and main lobby of the hotels”); Doe S.W., 2020 WL
1244192, at *5 (finding plaintiff had plausibly alleged a TVPRA violation, in part,
because she alleged that, “[o]n average, three to five Johns would enter and leave the
hotel guest room on a daily basis”); Doe 4, 2021 WL 12104819, at *7 (“Further, CC&S,
Kuzzins, and Essex knew or should have known the venture violated the TVPRA
because their employees, agents, and representatives saw the signs of sex trafficking
exhibited by Plaintiff, the condition of the rooms in which she was trafficked, the
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frequency and volume of traffic of male buyers to Plaintiff’s rooms, and the numerous
other victims being trafficked at the hotel which evidenced sex trafficking, as opposed to
mere prostitution.”).
Although P.C.’s complaint lacks important details such as where and how large
her bruises were, how many men visited the rooms of trafficking victims on a regular
basis, and who at the hotel served as lookouts, the Court finds that her complaint
presents sufficient factual allegations to nudge her claim from possible to plausible.
Khalik, 671 F.3d at 1190 (“A plaintiff must nudge [her] claims across the line from
conceivable to plausible in order to survive a motion to dismiss.” (quoting Twombly, 550
U.S. at 570)). The Court therefore denies D Fort’s motion to dismiss.
IV. 	CONCLUSION
Therefore, it is
ORDERED that the Motion to Dismiss [Docket No. 11] is DENIED. It is further
ORDERED that Plaintiff’s Motion to Proceed Under Pseudonym for Pretrial
Proceedings [Docket No. 22] is GRANTED.
DATED February 5, 2025.
BY THE COURT:
___________________________
PHILIP A. BRIMMER
Chief United States District Judge
_______________	_ ___________
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