---
title: "Expert’s General Opinions on Human Trafficking Excluded"
meta:
  "og:description": "The human trafficking expert was barred from offering case-specific opinions because her methodology was overly general"
  "og:title": "Expert’s General Opinions on Human Trafficking Excluded"
  author: "Expert Witness Profiler"
  description: "The human trafficking expert was barred from offering case-specific opinions because her methodology was overly general"
---

# Expert’s General Opinions on Human Trafficking Excluded

Posted on September 25, 2025 by Expert Witness Profiler

Jane Doe K.R. sued Defendants, Choice Hotels, Choice Hotels International, Inc., and Choice Hotels International Services Corp. under the Trafficking Victims Protection Reauthorization Act (TVPRA).

Plaintiff alleged that between March and May 2013, she was the victim of sex trafficking at an Orlando, Florida hotel owned and operated by WHG, a franchisee of the Choice Hotels Defendants.

In support of Plaintiff’s claims, [Rochelle Keyhan](https://expertwitnessprofiler.com/expert-witness/Rochelle-Keyhan/1568416) has provided an approximatelythirty-page report titled Expert Report on Human Trafficking: Victim Behaviors and Trafficker Actions. Defendants filed _[Daubert](https://www.law.cornell.edu/wex/daubert_standard)_ motions to exclude the opinions offered by Keyhan.

## **Human Trafficking Expert Witness**

[Rochelle Keyhan](https://expertwitnessprofiler.com/expert-witness/Rochelle-Keyhan/1568416) is the Chief Executive Officer of Collective Liberty and the 2018 Thomson Reuters Foundation Stop Slavery Hero award winner. She has 14 years of experience conducting anti-human trafficking investigations and prosecutions and 9 years as an expert advisor to over 2,000 investigations across the United States.

Keyhan received her Bachelor of Arts degree from UCLA and her law degree from Temple University.

[Fortify your strategy by reviewing a Challenge Study detailing grounds for excluding Rochelle Keyhan’s expert testimony](https://expertwitnessprofiler.com/order/add?eId=1568416&amp;pId=3).

## **Discussion by the Court**

In the report, Keyhan opined as to the Defendants’ knowledge of the trafficking of individuals at their properties in general and of Plaintiff’s trafficking at the Orlando hotel in particular. In addition, she opined as to the financial benefit that the Defendants derived by permitting trafficking as well as the Defendants’ failure to implement available anti-trafficking policies.

Moreover, in her report, Keyhan described her general methodology as involving data collection and analysis (including pattern recognition), collaboration with experts and organizations around the country, along with case studies of high-profile trafficking cases.

#### _**Analysis**_

Defendants contended that Keyhan is not qualified to offer these opinions, which are not based on a reliable methodology or helpful to the factfinder.

Furthermore, Keyhan testified that she had not reviewed anything specific to this case beyond the unverified complaint, and consequently, she could offer only general opinions on human trafficking. Nonetheless, the challenged opinions are specific to this case. They require sufficient facts about Defendants and the Orlando hotel to support conclusions about Defendants’ (actual or constructive) knowledge of trafficking there.

In addition, the opinions also require facts about Defendants’ financial situation and any anti-trafficking policies that Defendants had implemented. However, Keyhan’s deposition testimony showed that she lacked such facts: she could not recall reviewing Defendants’ franchise agreement and did not know what measures, if any, WHG SU Delegates had taken to address safety concerns at the Orlando hotel.

Meanwhile, Plaintiff faults Defendants for failing to timely provide case-specific documents, but Plaintiff bears the burden of establishing that Keyhan based her opinions on sufficient facts. Ultimately, the Court held that the methodology described in Keyhan’s report is too general to explain how she arrived at the opinions specific to this case.

## **Held**

The Court denied the Defendants’ _Daubert_ motions to exclude the testimony of Rochelle Keyhan.

## **Key Takeaway:**

Because Keyhan did not review the Defendant’s policies and procedures, she lacked any foundation to assert that the Defendant failed to adopt, implement, or enforce adequate training, processes, or protocols to address prostitution or human trafficking on their properties.

## **Case Details:**

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