Jane Doe (S.E.S., an individual) v. Choice Hotels International, Inc., et al.
D. Maryland11/25/2025
AI Case Brief
Generate an AI-powered case brief with:
đKey Facts
âïžLegal Issues
đCourt Holding
đĄReasoning
đŻSignificance
Estimated cost: $0.10â$0.50 per brief, depending on opinion length and retries
Full Opinion
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND : JANE DOE (S.E.S., an individual) : v. : Civil Action No. DKC 24-3776 : CHOICE HOTELS INTERNATIONAL, INC., et al. : MEMORANDUM OPINION Plaintiff Jane Doe (âPlaintiffâ) filed this Trafficking Victims Protection Reauthorization Act (âTVPRAâ) action against Choice Hotels International, Inc., Choice Hotels International Service Corp. (collectively, âChoice Defendantsâ),1 and Phillip Hall Properties, L.L.C. (âPHPâ). She alleges that she was the victim of sex trafficking at an Alabama hotel owned by PHP, the purported franchisee of Choice Defendants. Presently pending and ready for resolution in this TVPRA case is the motion to transfer venue to the United States District Court for the Southern District of Alabama or to dismiss filed by Choice Defendants. (ECF No. 18). The issues have been briefed, and the court now rules, no 1 Choice Defendants contend that Choice Hotels International Service Corp. is not a proper defendant to this case because â[i]t does not play any meaningful role in the activities described in the [complaint].â (ECF No. 18-1, at 10 n.1). Because the court will grant the motion to transfer venue, it does not reach any arguments regarding dismissal. Plaintiffâs allegations against the two entities are identical. hearing being deemed necessary. Local Rule 105.6. For the following reasons, the motion to transfer venue will be granted. Choice Defendantsâ alternative motion to dismiss, nonparty Trent Hallâs correspondence, and Plaintiffâs motion for leave to amend the complaint remain for resolution in the transferee district. I. Background A. Factual Background2 S.E.S., proceeding as Jane Doe, alleges that she was the victim of sex trafficking âan incalculable number of timesâ at a Quality Inn hotel in Mobile, Alabama, between July 2013 and at least December 2014. (ECF No. 14 ¶¶ 26, 30, 32). A franchisee of Choice Defendants operates the Quality Inn. (Id. ¶¶ 17â19). Doe alleges that her trafficker âforced [her] to engage in commercial sex acts numerous times a dayâ; he âwould drug her up and physically and/or mentally abuse her.â (Id. ¶ 27). She alleges that, when she tried to leave, he âwould beat her and/or threaten her.â (Id. ¶ 28). His actions put Doe âin constant fear for her life.â (Id. ¶ 27). As general background, Doe notes the particular prevalence of sex trafficking in the hotel industry. (Id. ¶ 34). She alleges that â[t]he signs of sex trafficking in a hotel environment follow 2 All facts herein are alleged in the operative complaint. 2 well-established patterns and can easily be detected by appropriately trained staff.â (Id. ¶ 38). Doe alleges that, given the strong connection between sex trafficking and the hotel industry, âreasonable diligence required treating signs of commercial sex activity, particularly with apparent and obvious involvement of a âpimp,â as evidence of sex trafficking[,] . . . [and] required Defendants to avoid benefiting from the rental of its rooms for commercial sex.â (Id. ¶ 42). Doe alleges that Choice Defendants and PHP âhave known, since well before [her] trafficking, that sex trafficking was ongoing and widespread at Choice Hotels branded properties including the [Quality Inn]â named in the complaint. (Id. ¶ 49). She contends that âeach of the Defendants monitored criminal activity [related to sex trafficking] occurring at Choice hotels branded propertiesâ and highlights news stories from around the country between 2004 and 2015 regarding sex trafficking at Choice Hotels branded properties. (Id. ¶¶ 50, 52). Doe then points to online reviews between 2006 and 2018 noting sex trafficking activity and apparent prostitution at Choice Hotels branded properties across the country. (Id. ¶ 55). She alleges that â[t]he common use of Choice Hotel branded hotels for sex trafficking became a nationwide problem that stemmed from decisions made at the corporate/franchisor level.â (Id. ¶ 56). 3 Doe next alleges that Choice Defendants and PHP âwere specifically aware that sex trafficking was widespread and ongoing at the Quality Innâ named in the complaint. (Id. ¶ 60). Reasoning upon information and belief that Choice Defendants âmanage and monitorâ internet reviews for the Quality Inn at issue, Doe highlights various internet reviews of the Quality Inn between 2015 and 2020 that repeatedly note the abundance of used condoms in rooms and apparent prostitutes on hotel premises. (See id. ¶ 62). Doe alleges that her trafficker and others âselected this [Quality Inn] because of policies and practices that created a favorable environment for trafficking and because hotel staff turned a blind eye to . . . well-known âred flagsâ for sex trafficking in the hospitality industry.â (Id. ¶ 63). Concerning her own trafficking, Doe lists numerous red flags that she alleges put hotel staff on notice that she was being trafficked. For example, â[t]he hotel rooms in which she was trafficked were frequently paid for with cash or prepaid cardsâ; the âDo Not Disturbâ sign was hung on her door for days at a time; Doe âwould give hotel management and/or employees âhushâ money not to report herâ; there was âheavy foot traffic in and out of [her] room involving men who were not hotel guests,â which hotel management noticed; and Doe âwas forced to see at least 5 johns 4 every day,â who would come and go at âunusual hoursâ and âfor brief periods of time.â (Id. ¶ 73). Doe alleges that, as a result, PHP and Choice Defendants knew or should have known of her sex trafficking. (Id. ¶¶ 75â76). Furthermore, she contends that Choice Defendants and PHP knowingly benefitted from her trafficking by continuing to rent rooms to her trafficker and others. (Id. ¶ 95). B. Procedural Background Plaintiff filed the operative three-count complaint on March 31, 2025, against PHP3 and Choice Defendants. (ECF No. 14). All counts arise under the TVPRA: Count I alleges perpetrator liability against PHP, Count II alleges beneficiary liability against PHP and Choice Defendants, and Count III alleges vicarious liability 3 Plaintiff appears to have named PHP as the franchisee defendant in error. She attempted to serve PHP unsuccessfully on multiple occasions, (ECF No. 15, at 2), before finally accomplishing service in April 2025, (ECF No. 26-2, at 5). She then learned that PHP was the incorrect party, an error she ascribes to the âunique address numbering system in Mobile, Alabama, that had incorrectly attributed the address of the Quality Inn where she was trafficked to the wrong entity.â (ECF No. 23- 1, at 2). Trent Hall, presumably related to Phillip Hall of PHP, has filed correspondence styled as a motion to dismiss in which he explains that PHP went out of business in 2010 and never owned the Quality Inn at issue. (ECF No. 21). Plaintiff has since filed a motion for leave to amend her complaint to substitute the proper franchisee defendant, which she identifies as Meenal LLC, an Alabama limited liability company registered and headquartered in Alabama, (ECF No. 23-3 ¶ 18), as well as to amend other allegations. The Choice Defendants oppose the motion. (ECF No. 26). 5 against Choice Defendants. (Id. ¶¶ 104â16). On April 14, 2025, Choice Defendants filed a motion to transfer venue to the Southern District of Alabama or, in the alternative, to dismiss. (ECF No. 18). Plaintiff filed her opposition on April 28, 2025. (ECF No. 24). Choice Defendants then filed their reply on May 12, 2025. (ECF No. 25). Since then, Choice Defendants have filed two notices of supplemental authorities regarding similar cases decided in this district. (ECF Nos. 31; 32). II. Analysis Choice Defendants move to dismiss or transfer for improper venue under Fed.R.Civ.P. 12(b)(3) and 28 U.S.C. § 1406. In the alternative, they move to transfer venue, even if proper in this district, under 28 U.S.C. § 1404(a). The venue statute provides two relevant bases to lay venue. First, venue is permissible in a âdistrict in which any defendant resides, if all defendants are residents of the State in which the district is located,â with residency of entities determined based on where they are subject to personal jurisdiction. 28 U.S.C. § 1391(b)(1), (c)(2). Second, venue is permissible in a âdistrict in which a substantial part of the events or omissions giving rise to the claim occurred.â Id. § 1391(b)(2). Choice Defendants argue that venue is improper in the District of Maryland because the court lacks personal jurisdiction over the franchisee defendant and a substantial part 6 of the events giving rise to Plaintiffâs claim did not occur in Maryland. (ECF No. 18-1, at 14â19). Although it may well be that the court lacks personal jurisdiction over the franchisee defendant and that a substantial portion of the relevant events did not occur here, it is not necessary to decide those questions because transfer under 28 U.S.C. § 1404(a) is available.4 See Doe (C.T.K.) v. Choice Hotels Intâl, Inc., No. 24-cv-2836-DLB, 2025 WL 2430024, at *3 (D.Md. Aug. 22, 2025) (â[W]hen jurisdiction over a defendant is doubtful, âtransfer is often the better course.ââ (quoting Pilz v. Pere, No. 07-cv-1314-CCB, 2007 WL 2572433, at *1 (D.Md. Aug. 30, 2007))). Section 1404(a) provides that âa district court may transfer any civil action to any other district or division where it might have been broughtâ if doing so is to âthe convenience of parties and witnessesâ and âin the interest of justice.â 28 U.S.C. § 1404(a). âThe threshold question on a motion to transfer is whether the action might have been brought in the transferee forum.â Howard Univ. v. Watkins, No. 06-cv-2076-DKC, 2007 WL 763182, at *3 (D.Md. Mar. 12, 2007). In other words, the court must assure itself that âvenue and personal jurisdiction are proper 4 Because all of Plaintiffâs claims arise under federal law, there are no choice of law consequences to proceeding under § 1404 rather than § 1406. 7 in the transferee forum.â Corry v. CFM Majestic Inc., 16 F.Supp.2d 660, 663 (E.D.Va. 1998). As to venue, it is uncontested that this case could have been brought in the Southern District of Alabama. A âsubstantial part of the events or omissions giving rise to the claimâ occurred in the Southern District of Alabama because that is where Doe alleges the sex trafficking took place. 28 U.S.C. § 1391(b)(2). Personal jurisdiction is straightforward, too. A forum has personal jurisdiction over a defendant if the defendant has âcertain minimum contacts with it such that the maintenance of the suit does not offend âtraditional notions of fair play and substantial justice.ââ Intâl Shoe Co. v. Washington, 326 U.S. 310, 316 (1945) (quoting Milliken v. Meyer, 311 U.S. 457, 463 (1940)). The Supreme Court of the United States has split the personal jurisdiction analysis into two branches: specific and general. A court may exercise specific jurisdiction over a defendant when the âsuit aris[es] out of or relate[s] to the defendantâs contacts with the forum.â Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 414 & n.8 (1984). On the other hand, courts may exercise general jurisdiction over the defendant if the defendant is at home in the forumâmeaning, for business entities, that the forum is the defendantâs place of incorporation or principal place of businessâeven if the suit is 8 unrelated to the defendantâs forum contacts. See Daimler AG v. Bauman, 571 U.S. 117, 127, 137 (2014). At the very least, the proper franchisee defendant here is subject to specific personal jurisdiction in the Southern District of Alabama because the alleged sex trafficking arose out of the franchiseeâs operation of a hotel there.5 The Choice Defendants would likewise be subject to specific personal jurisdiction in the Southern District of Alabama, as their counsel has expressly acknowledged in at least one other case within this district. Doe (J.S.H.) v. Choice Hotels Intâl, Inc., No. 24-cv-1598-TDC, 2025 WL 2108792, at *12 (D.Md. July 28, 2025) (â[A]s acknowledged at the hearing by Defendants, personal jurisdiction would exist [in the transferee forum] over . . . Choice.â). Even if Choice were to change its position, Judge Boardman observed that âin other nearly identical TVPRA cases, courts have agreed that the court in a franchiseeâs home jurisdiction may exercise personal jurisdiction over an out-of- 5 It is quite likely that the proper franchisee defendant is at home in the Southern District of Alabama and thus subject to general jurisdiction there. In her proposed second amended complaint, Plaintiff alleges that the proper franchisee defendant is Meenal LLC, an entity registered and headquartered in Alabama. (ECF No. 23-2 ¶ 18). Due to Plaintiffâs failure to identify the proper franchisee entity at the outset, however, the court lacks sufficient facts to reach such a conclusion. 9 state franchisor.â Doe (C.T.K.), 2025 WL 2430024, at *4 (collecting cases). Therefore, this case could have been brought in the Southern District of Alabama, satisfying the § 1404(a) threshold inquiry. Once satisfied that the moving party has met this threshold requirement, courts in the United States Court of Appeals for the Fourth Circuit apply a four-factor test to transfer motions: â(1) the weight accorded to plaintiffâs choice of venue; (2) witness convenience and access; (3) convenience of the parties; and (4) the interest of justice.â Trs. of the Plumbers and Pipefitters Natâl Pension Fund v. Plumbing Servs., Inc., 791 F.3d 436, 444 (4th Cir. 2015) (citing, inter alia, Lynch v. Vanderhoef Builders, 237 F.Supp.2d 615, 617 (D.Md. 2002)). âThe burden is on the moving party to show that transfer to another forum is proper.â Gilbert v. Freshbikes, LLC, 32 F.Supp.3d 594, 607 (D.Md. 2014) (citing Cross v. Fleet Rsrv. Assân Pension Plan, 383 F.Supp.2d 852, 856 (D.Md. 2005)). âSection 1404(a) reflects an increased desire to have federal civil suits tried in the federal system at the place called for in the particular case by considerations of convenience and justice.â Van Dusen v. Barrack, 376 U.S. 612, 616 (1964). While courts frequently defer to a plaintiffâs choice of forum, such âdeference is not limitless . . . and can be overcome.â Gilbert, 32 F.Supp.3d at 607 (citing Lynch, 237 F.Supp.2d at 617). 10 Ultimately, â[t]he decision whether to transfer venue is committed to the sound discretion of the trial court.â Hausfeld v. Love Funding Corp., 16 F.Supp.3d 591, 604 (D.Md. 2014) (alteration in original) (quoting Mamani v. Bustamante, 547 F.Supp.2d 465, 469 (D.Md. 2008)). A. Plaintiffâs Choice of Forum âWhere a plaintiff sues in her home forum, her choice of venue is âordinarily accorded considerable weight.ââ Hausfeld, 16 F.Supp.3d at 604 (quoting Lynch, 237 F.Supp.2d at 617). Such deference âis lower when the plaintiff is not [a] citizen of the [forum] state or the case does not otherwise have âsignificant tiesâ to the forum.â Doe (J.S.H.), 2025 WL 2108792, at *10 (quoting Carey v. Bayerische Hypo-Und Vereinsbank AG, 370 F.3d 234, 237â38 (2d Cir. 2004)); see also Sinochem Intâl Co. v. Malaysia Intâl Shipping Corp., 549 U.S. 422, 430 (2007) (âWhere the plaintiffâs choice is not its home forum, however, the presumption in the plaintiffâs favor âapplies with less force.ââ (quoting Piper Aircraft Co. v. Reyno, 454 U.S. 235, 255 (1981))). Plaintiff Doe is a citizen of Alabama, not Maryland. (ECF No. 14 ¶ 11). Moreover, every other court in this district to have considered a substantially identical case has concluded that whatever ties Maryland does have to the caseâbecause of potential acts or omissions at Choice headquartersâare not significant 11 enough to warrant substantial deference to the out-of-state Plaintiffâs choice of forum. See Doe (J.S.H.), 2025 WL 2108792, at *11; Doe (J.L.K.) v. Choice Hotels Intâl, Inc., No. 24-cv-3774- GLR, 2025 WL 2197035, at *6 (D.Md. Aug. 1, 2025); Doe (C.T.K.), 2025 WL 2430024, at *5; Transcript of Motions Hearing at 67, Doe (P.T.L.) v. Choice Hotels Intâl, Inc., No. 24-cv-3775-PX (D.Md. Aug. 26, 2025), ECF No. 43; Doe (A.E.W.) v. Choice Hotels Intâl, Inc., No. 24-cv-3769-TDC, 2025 WL 2468510, at *11 (D.Md. Aug. 27, 2025). The alleged sex trafficking underpinning this case took place entirely in Alabama, not Maryland. See Intâl Painters & Allied Trade Indus. Pension Fund v. Marrero Glass & Metal Inc., No. 18-cv-452-ELH, 2019 WL 423409, at *4 (D.Md. Feb. 1, 2019) (attaching little weight to the plaintiffâs choice of forum when âthe disputed conduct, or lack thereof, underlying the Complaintâ occurred outside the forum). Plaintiff cites A.M.G. v. Red Roof Inns, Inc., No. 23-cv- 4195, 2025 WL 588645 (S.D.Ohio Feb. 24, 2025), for the proposition that a âplaintiffâs choice to file in the principal place of business of [the] franchisor [is] entitled to deference in a TVPRA case.â (ECF No. 24, at 15 n.21). The A.M.G. court, in an unpublished trial court decision denying the motion to transfer, recognized that âwhere âthe cause of action has little connection with the chosen forum,â a plaintiffâs choice of forum is given 12 less weight than such choice would be given otherwise.â A.M.G., 2025 WL 588645, at *7 (quoting DRFP, LLC v. Republica Bolivariana de Venezuela, 945 F.Supp.2d 890, 902â03 (S.D.Ohio 2013)). Other courts have adopted a sliding scale approach. See Carey, 370 F.3d at 237â38 (affirming diminished deference to plaintiffâs choice of forum in proportion to diminished connection between the forum and the case). Marylandâs ties to this case comprise the most tenuous portions of Plaintiffâs complaint. Accordingly, deference to the Plaintiffâs choice of forum is considerably diminished. For these reasons, this factor does not weigh significantly against transfer. B. Convenience of the Witnesses âThe convenience of the witnesses is âperhaps the most important factorâ in determining whether a transfer of venue should be granted.â Mamani, 547 F.Supp.2d at 473 (quoting Cronos Containers Ltd. v. Amazon Lines, Ltd., 121 F.Supp.2d 461, 466 (D.Md. 2000)). Choice Defendants argue that the relevant witnesses, including âPlaintiffâs alleged trafficker, hotel staff, knowledgeable law enforcement personnel, doctors, and other damages witnesses,â are likely located in Alabama. (ECF No. 18- 1, at 20â21). Choice Defendants add that this court also âmight be unable to compel [those Alabama witnesses] to attend a trial in 13 the District of Marylandâ due to the limits of this courtâs subpoena power under Fed.R.Civ.P. 45(c). (Id. at 21 (alteration in original) (quoting Elliot AmQuip, LLC v. Bay Elec. Co., No. 10- cv-3598-ELH, 2011 WL 2174893, at *9 (D.Md. June 2, 2011))); see also Fed.R.Civ.P. 45(c)(1)(A) (âA subpoena may command a person to attend a trial, hearing or deposition only,â in relevant part, âwithin 100 miles of where the person resides, is employed, or regularly transacts business in person[.]â). Plaintiff counters that Defendant has not met its burden as the moving party to show âspecific hardship,â and the passage of ten years since the trafficking suggests that many of the witnesses no longer reside in Alabama. (ECF No. 24, at 15). Moreover, the witnesses related to corporate knowledge and conduct, Plaintiff contends, are located in Maryland. (Id. at 16). To Defendantsâ Rule 45(c) concern, Plaintiff responds that the court can compel witnesses to attend video depositions, which would be admissible at trial. (Id.). Choice Defendantsâ arguments are more persuasive. At the outset, Choice Defendantsâ burden on specificity is lessened by the fact that Plaintiff proceeds under pseudonym, has not identified her trafficker, and alleges a long period of trafficking. It is difficult to assess the inconvenience to particular witnesses when the facts alleged do not give Choice 14 Defendants reasonable and adequate notice of who all relevant witnesses may be. The convenience inquiry must therefore proceed at a higher level of generality. Choice Defendants are almost certainly correct that nearly all the relevant witnesses were at least once located in Alabama. Whether they remain there is unclear, but mere speculation that some have moved away is insufficient to defeat the commonsense conclusion that Alabama is the likely locus of relevant witnesses. Regarding compulsory process, Plaintiff is correct that witnesses can attend video depositions, but that does not fully address the concern that the court could not compel the witnessesâ in-person presence at trial. See Doe (C.T.K.), 2025 WL 2430024, at *5. The Southern District of Alabama is the more convenient forum for the witnesses. This factor therefore weighs in favor of transfer. C. Convenience of the Parties â[A] transfer of venue that merely switches the inconvenience from one party to the other generally will be refused.â Pinpoint IT Servs., L.L.C. v. Atlas IT Export Corp., 812 F.Supp.2d 710, 721 (E.D.Va. 2011) (citing 15 Wright & Miller, Federal Practice and Procedure § 3849 (3d ed. 2007)). That is unlikely to be the case here. Ironically, transfer here, from the headquarters of Choice Defendants to Plaintiffâs home jurisdiction, is said to switch the 15 inconvenience as between Plaintiff and Choice Defendants. Undoubtedly, the transfer will render the litigation more convenient to the franchisee defendant. Plaintiff evidently named the wrong franchisee defendant, PHP, but the parties appear now to have identified the correct franchisee defendant, an Alabama limited liability company. (ECF Nos. 23-2 ¶ 18; 26-2). Although this entity has not had a chance to weigh in, the logical assumption is that it is more convenient for an Alabama entity to litigate in Alabama than in Maryland. Plaintiff also argues that it is more convenient to litigate in Maryland because of âthe potential benefits of centralizing related TVPRA cases against Choice in this District.â (ECF No. 24, at 16). The five other TVPRA cases against Choice Defendants in this district of which the court is aware, however, have all been transferred to other districts. See Doe (J.S.H.), 2025 WL 2108792, at *13 (transferring the case to the Middle District of Florida); Doe (J.L.K.), 2025 WL 2197035, at *7 (District of Idaho); Doe (C.T.K.), 2025 WL 2430024, at *7 (Eastern District of Wisconsin); Transcript of Motions Hearing at 70, Doe (P.T.L.), No. 24-cv-3775-PX, ECF No. 43 (Eastern District of Louisiana); Doe (A.E.W.), 2025 WL 2468510, at *13 (Eastern District of Pennsylvania). Consequently, there is little left to centralize. 16 The Southern District of Alabama is at least marginally more convenient to the parties overall. This factor thus tilts in favor of transfer. D. Interest of Justice Whether transfer is in the interest of justice is an âamorphous and somewhat subjectiveâ assessment in which the court may account for a litany of other relevant considerations. Doe (J.L.K.), 2025 WL 2197035, at *7 (quoting Gennari Consulting, Inc. v. Wellington Corp., LLC, No. 19-cv-1851-ELH, 2019 WL 6829102, at *9 (D.Md. Dec. 13, 2019)). â[A]voiding duplicative litigationâ is one such consideration. Id. (quoting Capitol Payment Sys., Inc. v. Di Donato, No. 16-cv-882-ELH, 2017 WL 2242678, at *14 (D.Md. May 23, 2017)). Accordingly, â[c]ourts in this district have found the interest of justice favors transfer when personal jurisdiction over an indispensable party is a close question.â Doe (C.T.K.), 2025 WL 2430024, at *6 (collecting cases). Here, it is highly doubtful the court could exercise personal jurisdiction over the franchisee defendant. The parties indicate that the proper franchisee defendant is an Alabama limited liability company registered and headquartered in Alabama. Therefore, it would not be subject to general jurisdiction in Maryland. Plaintiff would need to establish specific jurisdiction over the franchisee defendant in Maryland. In the five other TVPRA 17 cases against Choice in this district, four courts have found specific jurisdiction over the franchisee defendant lacking. See Doe (J.S.H.), 2025 WL 2108792, at *9 (holding that the alleged sex trafficking did not arise out of or relate to the franchiseeâs contact with Maryland, namely the franchise agreement); Doe (J.L.K.), 2025 WL 2197035, at *3â4 (same); Transcript of Motions Hearing at 61â63, Doe (P.T.L.), No. 24-cv-3775-PX, ECF No. 43 (same); Doe (A.E.W.), 2025 WL 2468510, at *9 (same). One court found such specific jurisdiction âhighly doubtful.â Doe (C.T.K.), 2025 WL 2430024, at *6. The reasoning in these materially indistinguishable cases is persuasive, raising significant doubts about the assertion of specific jurisdiction over the franchisee defendant in this case. If the franchisee defendant is indeed not subject to specific jurisdiction here, Plaintiff would need to bring her claims against the franchisee defendant separately in Alabama. Such duplicative litigation is precisely what this factor seeks to avoid. It would also be wholly unnecessary because Choice Defendants are likely subject to specific jurisdiction in the Southern District of Alabama. That district is the appropriate forum because it is likely the only forum in which Plaintiff can assert her claims against all defendants in the same litigation. See Aphena Pharma Sols.-Md. LLC v. BioZone Labâys, Inc., 912 F.Supp.2d 309, 320â21 18 (D.Md. 2012) (holding that the interest of justice required transfer to avoid splitting the litigation, despite none of the other factors favoring transfer). Another consideration under this factor is the âinterest in having local[] controversies decided at home.â Hausfeld, 16 F.Supp.3d at 605 (quoting Atl. Marine Constr. Co. v. U.S. Dist. Ct. for the W. Dist. of Tex., 571 U.S. 49, 62 n.6 (2013)). Plaintiff and Choice Defendants dispute whether Maryland or Alabama has a greater interest in this controversy. (Compare ECF No. 18-1, at 22, with ECF No. 24, at 17). Courts in this district to consider this particular issue have concluded that the state of the franchisee where the alleged sex trafficking occurred has a greater interest than the state of the franchisor. E.g., Doe (J.S.H.), 2025 WL 2108792, at *12 (â[T]his case has relatively stronger ties to Florida, where the sex trafficking actually occurred[.]â). The court need not decide that issue here. Even if Maryland did have a marginally greater interest, that would not outweigh the imperative of keeping the litigation intact. See Aphena, 912 F.Supp.2d at 320â21.6 The interest of justice strongly favors transfer. * * * 6 Plaintiff also raises her centralization argument here again. As explained, however, there is nothing left to centralize in this district. 19 In sum, Plaintiffâs choice of forum is not entitled to meaningful deference, transfer is more convenient to the witnesses and parties, and transfer is strongly in the interest of justice. Accordingly, the court will transfer the case to the Southern District of Alabama, where Choice Defendantsâ alternative motion to dismiss, nonparty Trent Hallâs correspondence, and Plaintiffâs motion for leave to amend will remain for resolution. III. Conclusion For the foregoing reasons, Choice Defendantsâ motion to transfer venue to the United States District Court for the Southern District of Alabama will be granted. A separate order will follow. /s/ DEBORAH K. CHASANOW United States District Judge 20
Case Information
- Court
- D. Maryland
- Decision Date
- November 25, 2025
- Status
- Precedential