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What TVPRA Civil Liability Means – A Survivor’s Guide to Holding the Businesses That Enabled Their Trafficking Accountable

| by Ryan Cavanaugh

Most survivors know the criminal side of anti-trafficking law. That involves arrests, charges, and prosecutions. What far fewer people know is that the same body of federal law gives survivors a separate civil claim, not only against the trafficker, but against the businesses that knowingly profited while the trafficking was happening. That pathway lives in the TVPRA (Trafficking Victims Protection Reauthorization Act), and it has produced some of the most significant accountability verdicts in modern American legal history.

What the Law Actually Says

The original Trafficking Victims Protection Act (TVPA) was a criminal statute, passed in 2000. Three years later, in 2003, Congress added a private civil right of action, codified at 18 U.S.C. section 1595. In 2008, that civil claim was expanded so survivors could sue not only the person who trafficked them, but any business or individual that “knowingly benefits, financially or by receiving anything of value, from participation in a venture” it knew or should have known engaged in trafficking. In 2023, Congress amended the law again to cover anyone who “attempts or conspires to benefit,” closing a loophole that had produced a problematic court ruling.

A civil case under the TVPRA stands completely on its own. No criminal conviction is required, and the burden of proof is lower than in a criminal proceeding. You need a preponderance of the evidence, not proof beyond a reasonable doubt.

What a Survivor Has to Show to Sue a Business

To bring a TVPRA civil claim against a business, a survivor generally has to establish three things.

First, that the business received something of value from the arrangement, whether that was room revenue, banking fees, advertising income, or transportation fares.

Second, that the business had a continuous relationship with the trafficker, not just a one-time transaction.

Third, that the business knew, or under the circumstances should have known, that the venture involved trafficking. Courts have been clear that looking the other way on purpose is not a defense.

Who Has Been Sued

Hotels and motels are the most common defendants in TVPRA civil cases. Survivors have alleged that staff ignored cash payments, refused housekeeping, heavy foot traffic in and out of rooms, and even active law enforcement alerts for missing persons, and did nothing.

On July 14, 2025, a federal jury in Atlanta awarded $40 million to a survivor identified only as J.G. against Northbrook Industries, Inc., the operator of the United Inn and Suites in Decatur, Georgia. J.G. was 16 years old when she was trafficked at the hotel over a 40-day period, forced to have sex with at least a dozen men a day while hotel staff ignored what was happening in plain sight. The verdict, $10 million in compensatory damages and $30 million in punitive, was the first TVPRA civil case to reach a jury verdict anywhere in the country.

Banks have been defendants too. In 2023, JPMorgan Chase settled claims brought by Jeffrey Epstein survivors for approximately $290 million, resolving allegations that the bank kept Epstein as a client for years despite internal warnings about his conduct. Deutsche Bank settled a parallel claim for approximately $75 million. Forced labor cases have produced major verdicts as well. In David v. Signal International, a federal jury awarded approximately $14 million to five H-2B guest workers from India who were recruited under fraudulent promises of green cards and forced into labor at Gulf Coast shipyards after Hurricane Katrina.

What Survivors Can Recover

Economic damages cover medical costs, therapy, and lost income. Non-economic damages address pain and suffering. Punitive damages are available when the defendant’s conduct was willful or reckless, as the J.G. verdict makes it clear. Section 1595 also expressly provides for recovery of reasonable attorney fees, which is why trafficking survivor attorneys can take these cases on contingency, with no upfront cost to the survivor. For survivors who were minors at the time of certain federal sex offenses, a companion federal remedy under 18 U.S.C. section 2255 provides minimum liquidated damages of $150,000.

How Long Survivors Have to File

A TVPRA civil claim generally must be filed within 10 years of the trafficking violation. For survivors who were minors at the time, that 10-year clock generally doesn’t start until their 18th birthday. The Eliminating Limits to Justice for Child Sex Abuse Victims Act of 2022 went further, removing the federal civil deadline entirely for survivors of certain federal sex offenses committed against them as minors. That change is prospective since claims that were already time-barred before September 16, 2022 are not revived, but claims that were still live as of that date have no federal deadline.

Common Questions

Can I sue a hotel even if no one was criminally charged?
Yes. A civil claim under 18 U.S.C. 1595 is independent of any criminal case.

What kinds of businesses can be sued?
Hotels, motels, franchisors, banks, online platforms, transportation companies, labor contractors, and any other entity that knowingly benefited from a trafficking venture it knew or should have known about.

Will my name be public?
Many survivors file under a pseudonym or initials. Federal courts have regularly permitted this in trafficking cases.

What does a consultation cost? Nothing. Constant Legal Group offers free, confidential consultations with no obligation and no upfront cost.

We Are Here to Hear Your Story

Federal law gives trafficking survivors the right to hold the businesses that enabled their exploitation accountable. Constant Legal Group pursues TVPRA civil claims nationally on behalf of survivors. We only get paid if we recover compensation for you.
Call us at 855-906-2561

This article is for informational purposes only and does not constitute legal advice. Contact Constant Legal Group for a confidential evaluation specific to your circumstances. Case outcomes vary significantly based on the specific facts of each case, jurisdiction, and applicable law.

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