David Bouchard Publishes Article in Law360 About the Disconnect Between District Courts Over the Civil Remedy Available to Sex Trafficking Survivors

Since early 2019, sex trafficking survivors have filed dozens of lawsuits against hospitality industry participants in federal courts nationwide under Title 18 U.S. Code Section 1595(a), the civil remedy included in the Trafficking Victims Protection Act, or TVPA.

In a series of recent orders on motions to dismiss filed by hotels, a split has emerged between federal district courts over whether a plaintiff suing under Section 1595(a)'s civil remedy must plausibly allege a defendant's conduct violated Section 1591(a)'s criminal standard. The article addresses the analytical fault lines by profiling a decision from the U.S. District Court for the Eastern District of Pennsylvania denying a motion to dismiss filed by Marriott International Inc. To read the full article, go here.

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