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Liberty Mutual must pay hotel’s defense costs in sex trafficking cases - Business Insurance Skip to content Register for free Search Search Log In Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Liberty Mutual must pay hotel’s defense costs in sex trafficking cases by Richard Sine Coverage Disputes , General liability Liberty Mutual Mar 23, 2026 Liberty Mutual must defend Red Roof Inns against a series of civil sex trafficking lawsuits, a federal judge ruled last week, finding that the hotel chain’s commercial general liability policies cover the costs. In Red Roof Inns Inc. et al. v. Liberty Mutual Fire Insurance Co. , Chief Judge Sarah D. Morrison of the U.S. District Court for the Southern District of Ohio ruled in favor of Red Roof on the issue of the insurer’s duty to defend but said determination of claims related to possible damages should be decided later. The case stems from 11 pending lawsuits against Red Roof brought under the federal Trafficking Victims Protection Reauthorization Act, in which plaintiffs allege they were trafficked for sex at Red Roof hotels and that the company financially benefited from the crime. Liberty Mutual, which issued Red Roof’s commercial general liability policies between 2011 and 2017, had denied coverage and refused to provide a defense. The central legal question was whether the trafficking claims constituted an “occurrence” — defined in the policies as an accident — triggering Liberty Mutual’s duty to defend, according to the ruling. Liberty Mutual argued that the trafficking law’s requirement that a defendant “participate in a venture” implied an intent to cause harm, voiding coverage. Judge Morrison, however, ruled that civil liability under the law does not require proof of intent to cause harm, noting that the statute’s “knew or should have known” language reflects a negligence standard. The court also rejected Liberty Mutual’s argument that the doctrine of inferred intent applied, reasoning that renting a room to a trafficker does not necessarily result in harm without an independent criminal act by a third party. “While perhaps the ‘true facts’ will one day show that Red Roof’s ‘conduct was outside the coverage of the policy,’ Liberty is obligated to defend Red Roof in the meantime,” she wrote. Federal civil sex trafficking cases filed under trafficking act have risen sharply since 2019, to 131 cases in 2023, the last year for which numbers are available, according to the Human Trafficking Legal Center. 55% of those cases involved hotels and the hospitality industry. Liberty Mutual declined to comment on the ruling. 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