## Facts

- A.D. alleged that she was subjected to commercial sex trafficking at hotels in Florida.
- A.D. sued multiple hotel-related entities, including LaQuinta Holdings, Inc., Choice Hotels International, Inc., Wyndham Hotels & Resorts, Inc., and other hotel owners and operators (collectively, the hotel parties).
- A.D. brought civil claims under the Trafficking Victims Protection Reauthorization Act (TVPRA), seeking damages under 18 U.S.C. § 1595 based on allegations that the hotel parties financially benefited from room rentals tied to trafficking and failed to act despite alleged indicators of trafficking activity.
- Choice Hotels moved to sever, arguing that A.D. improperly joined numerous hotel parties in a single action even though the claims involved different hotels, different ownership/operational structures, and different alleged events.
- The court considered whether the hotel parties were properly joined under the federal joinder rules and, if not, whether the case should be split into separate actions.

## Issues

1. Whether A.D.’s claims against multiple hotel parties satisfied Federal Rule of Civil Procedure 20’s requirements for permissive joinder of defendants (same transaction or occurrence, or series of transactions or occurrences, and common questions of law or fact).
2. If the hotel parties were misjoined, whether the court should sever the claims under Federal Rule of Civil Procedure 21 into separate actions.

## Decision

- The court granted Choice Hotels’ motion to sever.
- The court determined that the hotel parties were improperly joined and directed that the claims proceed in separate, appropriately grouped actions rather than as one multi-defendant case.

## Legal Principles

- Federal Rule of Civil Procedure 20 permits multiple defendants to be joined in one action only when the claims against them arise out of the same transaction or occurrence (or series of transactions or occurrences) and share at least one common question of law or fact.
- Federal Rule of Civil Procedure 21 authorizes a court to sever claims or parties when joinder is improper; severance may be ordered to avoid confusion, unfairness, and unwieldy case administration.
- When claims are tied to different properties and different sets of ownership and operational entities, joinder may be improper even if the claims are based on the same statute and similar legal theories.
- In multi-defendant TVPRA civil actions, case management tools such as severance may be used to ensure that each defendant receives clear notice of the claims asserted against it and to keep discovery and proof focused on the relevant property and defendant group.

## Conclusion

In A.D.’s TVPRA action against several hotel companies and related entities, the court held that the defendants were not properly joined in a single suit and ordered severance so that the claims would proceed in separate, hotel-specific actions.


A.D. v. LaQuinta Holdings, Inc.; Choice Hotels International, Inc.; Wyndham Hotels & Resorts, Inc.; et al., 2022 WL 4357989 (2022)