B.C. v. G6 Hospitality Property LLC
3:25-cv-05057
| W.D. Wash. | Jul 3, 2025Background
- Plaintiff, B.C., alleges she was sex trafficked at a Motel 6 in Tacoma, WA, from 2017-2020, while underage for part of the period.
- Plaintiff alleges G6 Hospitality Property LLC (G6), as owner/operator/franchisor of the motel, knowingly benefited from renting rooms to her traffickers.
- The complaint asserts visible trafficking “red flags” (bruises, suspicious activity, impaired victims) were observed by hotel staff.
- Plaintiff claims G6 failed to implement or follow anti-trafficking policies, and this failure proximately caused her harm and suffering.
- G6 moved to dismiss under Rule 12(b)(6), arguing Plaintiff failed to plead knowledge or participation in trafficking under the TVPRA.
- The court granted the motion to dismiss but permitted Plaintiff to amend her complaint within 60 days.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether G6 is liable under the TVPRA for sex trafficking | G6 received financial benefit from trafficking and ignored red flags; failed anti-trafficking efforts enabled harm | No plausible facts show G6 knew of trafficking or participated in a venture; allegations are conclusory | Dismissed for failure to state a claim, but leave to amend granted |
| Sufficient pleading of knowledge or participation | Alleged regular staff interaction, visible injuries, frequent suspicious activity | No specific facts linking staff knowledge to trafficking or G6's control over hotel | Insufficiently pled: complaint lacks specific facts to support knowledge/participation |
| Direct vs. indirect (agency) liability under TVPRA | G6 and its agents, staff, and employees all contributed to the trafficking | Plaintiff fails to allege control or an agency relationship between G6 and hotel staff | Conclusory allegations about agency/operation insufficient |
| Adequacy of allegations connecting G6 to traffickers | Continuing business relationship and repeated room rentals to traffickers | Only general allegations without detail; no “dot connection” to G6 as franchisor | Not enough facts to connect franchise/parent (G6) to specific trafficking conduct |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (establishes plausibility requirement for pleadings under Rule 12(b)(6))
- Keniston v. Roberts, 717 F.2d 1295 (9th Cir. 1983) (complaint construed in the plaintiff’s favor on motion to dismiss)
- Balistreri v. Pacifica Police Dep’t, 901 F.2d 696 (9th Cir. 1988) (motion to dismiss standard for lack of sufficient facts under a cognizable legal theory)
- Ditullio v. Boehm, 662 F.3d 1091 (9th Cir. 2011) (interpreting civil action provision of the TVPRA)