Suresh & Durga, Inc.v.Doe
Jane Doe was 17 when trafficker Bryant Owens brought her to America’s Best Inn & Suites, where she was forced to sell sex, then assaulted and robbed. She alleged the motel knew sex trafficking and other crimes repeatedly occurred there and failed to use or train staff on basic security measures; employees allegedly delayed calling police when she sought help. The motel moved for summary judgment on her premises-liability negligence, negligent hiring and supervision, nuisance, and attorney-fee claims. The Court of Appeals affirmed denial of summary judgment on premises-liability negligence because the history of crime, the motel’s alleged awareness and security practices, and the link between those practices and Doe’s injuries created jury questions on foreseeability, breach, and causation. It declined to address negligent hiring, retention, training, or entrustment because the motel had not raised those grounds in its motion below. It vacated the rulings on nuisance and attorney fees and remanded: the trial court gave no reasons, and Doe’s nuisance theory was unclear. The ruling lets the premises-liability claim proceed; it does not decide liability.
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