Hotel Security Expert Was Not Allowed to Opine on the Adequacy of Training
Posted on October 10, 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.
According to Plaintiff’s hotel security expert, Salvatore Caccavale, “the incident involving Plaintiff was foreseeable and predictable. Inconsistent documented staff training and the failure to adhere to corporate policies contributed to the ease of [the] trafficking of [Plaintiff] at the subject hotel location. Hotel ownership [i.e., Defendants] and their employees should have recognized the correlation between drug use and trafficking at their hotel and collaborated with local law enforcement. It is reasonable to conclude that the hotel management and staff knew that [Plaintiff] was being trafficked.”
Defendants challenged Caccavale’s qualifications and the overall reliability of his methodology before making reliability and helpfulness arguments against each of his opinions.
Hotel Security Expert Witness
Salvatore Caccavale has over 40 years of experience as a hospitality business and security executive, both at the property level, and subsequently with oversight for the Americas for Hilton branded hotels.
Presented by HospitalityLawyer.Com, Caccavale is the recipient of the Thomas G. Davis Loss Prevention Lifetime Award, and the beneficiary of Hilton Hotel’s 2001 Global Spirit of Pride Award. Caccavale has been recognized and honored by many levels of local, state, and federal law enforcement agencies over the years for his assistance in executing their duties.
Discussion by the Court
Qualification
Defendants did not dispute that Caccavale is generally qualified to opine on matters related to hotel safety and security; however, they maintained that he cannot offer opinions as to human trafficking because he is not qualified in that area of expertise. The Court notes that each of Caccavale’s opinions in this case concerns hotel safety and security.
Methodology
Defendants described three ways in which Caccavale did not follow the methodology endorsed by the International Association of Professional Security Consultants. First, the Defendants asserted that Caccavale did not conduct threat and vulnerability assessments at the physical property, as required. Second, according to Defendants, Caccavale looked to calls for service without sufficiently contextualizing them with other crime records such as incident reports. Third, Defendants argued, Caccavale improperly relied on CrimeCast information postdating the alleged 2013 trafficking incident and could not provide details about how the CrimeCast report was compiled. However, regarding these points, Caccavale testified that he conducted a vulnerability assessment based on calls for service, the CrimeCast report, and online reviews of the hotel, and the CrimeCast report shows past crime risk scores for the area around the Orlando hotel in 2010.
While Caccavale’s opinion about the predictability of the alleged sex trafficking incident may be helpful in determining whether Defendants knew or should have known about Plaintiff’s alleged sex trafficking, he was not allowed to opine on the adequacy of the training at the Orlando hotel because Caccavale admitted to not knowing what training policies were in place at the time of the alleged sex trafficking incident.
Defendants challenged Caccavale’s statement that they “should have recognized the correlation between drug use and trafficking at their hotel.” Plaintiff responded that opining as to a correlation between drug use and trafficking does not equate to opining that drug use always indicates trafficking. The Court agreed. Moreover, the jury will be called upon to decide whether Defendants, through their management and staff, had actual or constructive knowledge of Plaintiff’s trafficking at trial. Therefore, Caccavale’s statement that “it is reasonable to conclude that the hotel management and staff knew that [Plaintiff] was being trafficked” amounts to an impermissible legal conclusion.
Held
The Court granted in part and denied in part Defendants’ Daubert motions concerning Salvatore Caccavale.
Key Takeaway:
The Court addressed Defendants’ general arguments on qualifications and methodology in addition to the opinion-specific arguments. Defendants’ opinion-specific arguments fare better than their general challenges to Caccavale’s qualifications and methodology but are not wholly persuasive. Caccavale’s testimony is helpful in determining whether Defendants knew or should have known about Plaintiff’s alleged sex trafficking.
Case Details:
| Case Caption: | Doe K.R. V. Choice Hotels Et Al |
| Docket Number: | 6:23cv1012 |
| Court Name: | United States District Court, Florida Middle |
| Order Date: | October 09, 2025 |
