Law Enforcement Expert Was Not Allowed to Opine on Trafficking at Hotels
Posted on November 28, 2025 by Expert Witness Profiler
This case arises under the Trafficking Victims Protection Reauthorization Act (TVPRA), which provides victims of sex trafficking a civil remedy against the perpetrators and beneficiaries of their trafficking. Plaintiff C.L.F. filed this action to recover for alleged harm she experienced from being trafficked at a Motel 6 in Wichita, Kansas, that she claims was owned and operated by the Defendants.
On August 21, 2025, C.L.F. filed the motion sub judice, seeking to exclude as irrelevant the testimony of Defendants’ designated law-enforcement expert witness Bill Woolf.
Law Enforcement Expert Witness
William “Bill” Woolf has spent over 15 years of experience in law enforcement, specializing in the investigation of human trafficking, organized criminal enterprises, narcotics, and gang-related crime.
He has conducted extensive fieldwork in identifying, investigating, and dismantling human trafficking networks, with a focus on both sex trafficking and labor trafficking operations occurring in a variety of settings, including hospitality environments.
Woolf is the Principal and Founder of The Woolf Group, a national consulting firm providing expert guidance on human trafficking prevention, investigation, training, and public policy.
Discussion by the Court
C.L.F. asked the Court to exclude all four opinions offered by Woolf. Namely, Woolf’s opinions that:
(1) “There is no evidence that trafficking involving CLF was identified or interdicted by law enforcement during the relevant period;”
(2) “Hotel staff are not trained, equipped, or authorized to investigate or intervene in suspected trafficking operations;”
(3) “In transient lodging environments, the investigative and intervention burden for human trafficking rests with law enforcement, not hotel personnel;” and
(4) “It is unreasonable to retroactively impose a higher duty of detection on hotel staff than the standard applied by law enforcement at the time.”
C.L.F. claimed that “all of Woolf’s opinions are red herrings that draw the jury’s attention to topics that have no bearing on the actual issues that must be decided in this case.”
Opinion 1
Woolf may not tell the jury there was “no evidence that trafficking involving C.L.F. was identified or interdicted by law enforcement during the relevant period.” This is irrelevant to understanding whether hotel staff knew or should have known of sex trafficking at the Wichita Motel 6. It is also misleading. Hearing that police officers had “frequent engagement with the subject properties” and that they made no reports or arrests for sex-trafficking related crimes would lead a juror to conclude that such conduct was absent. That distracts the jury from the pertinent inquiry. Numerous arrests for sex trafficking might put hotel employees on notice, but that logic does not follow from a total absence of arrests. Law enforcement may not have arrested anyone for trafficking at the Wichita Motel 6, but that in no way precludes hotel management and staff from being aware of ongoing sex-trafficking-related activity.
As such, the Court struck Woolf’s opinion as irrelevant and misleading.
Opinion 2
The Court struck Woolf’s second opinion as misleading. Investigating and/or intervening in human trafficking is not an element of the TVPRA and to suggest that Defendants’ employees were not trained or able to investigate, identify, or interdict trafficking injects elements into C.L.F.’s burden of proof that simply are not there. All that is required for C.L.F. to show is that Defendants’ employees were negligently aware of sex-trafficking-related activity on the property.
Opinion 3
The jury cannot hear Woolf’s third opinion. It would tell the jury that, since hotel staff lack the “access to confidential intelligence, interagency data, investigative tools, and legal mechanisms such as warrants and subpoenas” that police officers have, hotel staff are unable to “reliably assess” potential trafficking red flags.
This would seriously undercut the jury’s factfinding role. As said, hotel staff cannot escape imputing knowledge from their own observations of sex-trafficking-related activity just because they lack military-grade investigative tools. A janitor’s inability to petition a judge for an arrest warrant has no bearing on his awareness of sex trafficking if there were observable signs of trafficking in the hotel hallways. The jury, who “is solely responsible for determining the weight and credibility of the evidence,” should assess how Defendants’ staff interpreted those signs without assessing how a police officer would react.
Further, pointing out hotel staff’s lack of crime-prevention tools might mislead the jury to think that the TVPRA excuses liability where a defendant is unable to prevent sex trafficking. As the parties know, making that suggestion to the jury would be wholly inappropriate because “the TVPRA does not impose an affirmative duty to police and prevent sex trafficking” (nor excuse sex-trafficking liability because no duty to prevent exists). The relevant inquiry is whether hotel staff knew of trafficking, not if they prevented, or attempted to prevent, it.
Opinion 4
Woolf’s fourth opinion is simply a summary of his already discussed testimony. His claim that it is “unreasonable to retroactively impose a higher duty of detection” on hotel staff than law enforcement highlights the irrelevance of his other opinions. Discussion of law enforcement’s knowledge or lack thereof regarding trafficking at the Wichita Motel 6 has no effect on that of hotel management and staff. Referring to it would only mislead the jury. Woolf’s testimony appears designed to imply that Defendants were unaware of sex trafficking because law enforcement, with all its law-enforcement techniques, was also unaware. While sensible to think that a layperson would not detect an ongoing crime if a police officer in the same situation could not, that analogy is “non-helpful” here.
The standard is whether hotel staff knew of sex trafficking at their hotel. As explained, hotel staff are in a much different position than police officers to observe the day-to-day happenings at a hotel. The ways in which law enforcement and hotel staff acquire knowledge of sex trafficking at a hotel are completely different and to conclusively suggest to the jury that what was not observable to law enforcement was not observable to hotel staff is both untrue and unhelpful.
Rebuttal Opinions
Defendants pointed out that Woolf also offered rebuttal testimony to C.L.F.’s experts, and that C.L.F.’s motion did not request those rebuttal points to be excluded. C.L.F. responded that, if the Court excludes Woolf’s opinions, then it should also exclude his rebuttal opinions.
All four opinions asserted that it would be unreasonable to find that hotel staff were aware of sex trafficking at the Wichita Motel 6 because law enforcement, with its greater resources, tools, and training, was not. As explained, such testimony would only confuse the jury.
Rebuttal Opinion 2 responded to C.L.F.’s expert witnesses’ claims that hotel training was inadequate by pointing out that no industry standards about sex-trafficking awareness, such as the DHS Blue Campaign Hospitality Toolkit, existed until after this case’s relevant trafficking period.
The opinion also pointed out how “assertions by [C.L.F.’s law-enforcement expert] Christi Decouflé that G6 policies actively discouraged reporting to law enforcement are not substantiated by the record.” But this is straightforward impeachment. It did not help the jury to have Woolf provide such testimony. Impeaching a witness by highlighting inconsistencies between their testimony about documents and facts contained in and relating to those documents does not require specialized knowledge, nor even a live witness; instead, that is the role of counsel.
This Ruling Remains Good for Both the Goose and the Gander
Woolf’s testimony could only muddle things, as he would not testify about red flags observable or known to hotel employees. Instead, he wants to advise the jury on what law enforcement would or would not have known. This would not help the jury.
While Woolf’s testimony goes to Defendants’ actual or constructive knowledge about the trafficking, it is inappropriate as compared to other experts.
Decouflé’s testimony here is based on Defendants’ own policies, guests’ online reviews, and what potential sex-trafficking-related facts the hotel workers, not police, saw during the relevant time. She would testify to hotel-staff knowledge based on hotel-staff observations while Woolf would compare hotel-staff knowledge and training to police-officer knowledge and training. For a jury deciding what the hotel staff knew or should have known, the former is helpful; the latter is not. Woolf’s testimony is irrelevant.
Held
The Court granted Plaintiff’s motion to strike or exclude the testimony of Bill Woolf.
Key Takeaway:
The perspective of a trained law enforcement officer experienced in identifying, investigating, and intervening in cases of human trafficking—even within hospitality settings—would not help the jury understand or determine whether G6’s management or staff knew, or should have known, that sex trafficking was occurring at the Wichita Motel 6.
While Woolf indicated that he considered “the observable signs and behaviors that might have been available to hotel staff,” his opinions address only what law enforcement would understand and/or do in response to those observations.
Please refer to the blog previously published about this case:
Psychology Expert’s Opinion on Social-Media-Facilitated Sex Trafficking Admitted
Case Details:
| Case Caption: | Doe C.L.F. V. G6 Hospitality, LLC |
| Docket Number: | 1:23cv303 |
| Court Name: | United States District Court, Texas Eastern |
| Order Date: | November 17, 2025 |
