Defendant's Attorney: Gregory Louis Zunino

Description: Las Vegas, Nevada personal injury lawyers represented Plaintiffs, who sued Defendant on civil rights violation theories.


he plaintiffs divide the defendants into five groups for ease of reference: (1) “State Defendants;” (2) “City Defendants;” (3) “Escort Agency Defendants;” (4) “Strip Club Defendants;” and (5) “Brothel Defendants.” Id. at 5-6, 8-9. The State Defendants are Nevada Governor Steve Sisolak and Nevada Attorney General Aaron Ford, both sued in their official capacities. Id. at 5. The City Defendants are the City of Las Vegas, Clark County, and Nye County. Id. at 6. The Escort Agency Defendants are Jamal Rashid; Mally Mall Music, LLC;

Future Music, LLC; PF Social Media Management, LLC; E.P. Sanctuary; Blu Magic Music, LLC; Exclusive Beauty Lounge, LLC; First Investment Property LLC; V.I.P. Entertainment, LLC; MP3 Productions, Inc.; and MMM Productions, Inc. Id. at 8. The Strip Club Defendants are SHAC, LLC doing business as Sapphire Gentleman's Club; SHAC MT, LLC; and Las Vegas Bistro doing business as Larry Flynt's Hustler Club. Id. The Brothel Defendants are Western Best LLC and Western Best, Inc. doing business as the Chicken Ranch. Id. at 9. The plaintiffs refer to the Escort Agency, Strip Club, and Brothel Defendants collectively as the “Sex Industry Defendants.” Id.

Williams alleges that when she was 17 years old, non-party Andre McDaniels trafficked her in Houston. Id. at 27-28. She alleges that from 2006 to 2017, her victimization continued in Nevada, California, Illinois, and Texas under the control of another trafficker, defendant Jamal Rashid, and his affiliates, the Escort Agency Defendants. Id. at 27, 34. Her ordeal in Nevada also included being trafficked “through the strip club[] . . . Sapphire [Gentleman's Club],” which is one of the Strip Club Defendants. Id. at 35.

Jane Doe #1 alleges that she was trafficked from a young age. Id. at 37. While she does not specify where her trafficking began, a family member eventually “induced her to travel to Las Vegas” where multiple non-party pimps trafficked her from 2013 to 2018. Id. at 37-38. During this period, she was also trafficked in New York, New Jersey, Colorado, Oregon, Texas, New Mexico, California, Oklahoma, Arizona, and Georgia. Id. at 38. At some point, she “became engaged in legal brothel prostitution at the Chicken Ranch while being pimped by” non-party traffickers. Id. at 40. She further alleges that the Chicken Ranch, a Brothel Defendant, subjected her to debt bondage in the course of her employment. Id. at 41-42.

Jane Doe #2 claims that she was trafficked in Houston from the age of 18. Id. at 42. Eventually, she travelled to Las Vegas where a series of non-party pimps trafficked her through Sapphire Gentleman's Club and Larry Flynt's Hustler Club, both Strip Club Defendants. Id. at 42-43. She contends that the Strip Club Defendants, like the Brothel Defendants, engaged in a form of debt bondage and were complicit in sexual abuses by clients. Id. at 46-48. Jane Doe #2's ordeal in Nevada spanned from March 2017 to September 2018. Id. at 42.

The plaintiffs allege that different subgroups of Sex Industry Defendants perpetrated and benefited from their trafficking in violation of the Thirteenth Amendment and the TVPRA. See generally id. While the plaintiffs were separately trafficked and their ordeals relative to one another were distinct, they contend that these experiences are collectively attributable to Nevada's system of legalized prostitution because “legal trade correlates with exponential increases in the illegal trade.” Id. at 18. Given this alleged correlation, the plaintiffs assert the same Thirteenth Amendment and TVPRA claims against the State and City Defendants, seeking a declaration that Nevada's system of legal prostitution is unconstitutional, and seeking to enjoin that system. Id. at 3, 54.

Seven motions are pending. Clark County moves to strike the First Amended Complaint or, in the alternative, to dismiss. ECF No. 53. Its motion is joined by the remaining City Defendants, the State Defendants, and the Brothel Defendants. ECF Nos. 58; 69; 71; 99. The Brothel Defendants, Strip Club Defendants SHAC, LLC and SHAC, MT LLC (collectively, the Sapphire Club), and the State Defendants move separately to dismiss. ECF Nos. 98; 133; 168. The plaintiffs move to strike excess pages in Clark County's reply to their opposition to its motion to dismiss. ECF No. 95. Clark County moves to strike three errata filed by the plaintiffs to add the language “oral argument requested” to each of their first three briefs opposing dismissal. ECF No. 164. Finally, Russell G. Greer moves to intervene as a defendant.
ECF No. 105.

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Article III of the Constitution “limits the jurisdiction of federal courts to ‘[c]ases' and ‘[c]ontroversies.'” Lance v. Coffman, 549 U.S. 437, 439 (2007). “A suit brought by a plaintiff without Article III standing is not a case or controversy, and an Article III federal court therefore lacks subject matter jurisdiction over the suit.” Braunstein v. Ariz. Dep't of Transp., 683 F.3d 1177, 1184 (9th Cir. 2012) (simplified). The “irreducible constitutional minimum of [Article III] standing consists of three elements.” Spokeo, Inc. v. Robins, 578 U.S. 330, 338 (2016) (simplified). “The plaintiff must have (1) suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial decision.” Id. Each element of Article III standing “must be supported in the same way as any other matter on which the plaintiff bears the burden of proof, i.e., with the manner and degree of evidence required at the successive stages of the litigation.” Lujan v. Defs. Of Wildlife, 504 U.S. 555, 561 (1992).

Outcome:
I THEREFORE ORDER that defendant Clark County's motion to dismiss (ECF No. 53) is GRANTED in part. I dismiss with prejudice the plaintiffs' claims against the City and State Defendants (Clark County, Nye County, the City of Las Vegas, Steve Sisolak, and Aaron Ford). I deny Clark County's motion to the extent it requests I strike the First Amended Complaint.

I FURTHER ORDER that plaintiffs Angela Williams, Jane Doe #1, and Jane Doe #2's motion to strike (ECF No. 95) is DENIED as moot.

I FURTHER ORDER that the State Defendants' (Steve Sisolak and Aaron Ford's) motion to dismiss (ECF No. 168) is DENIED as moot.

I FURTHER ORDER that the Brothel Defendants' (Western Best LLC and Western

Best, Inc.'s) motion to dismiss (ECF No. 98) is GRANTED in part. I dismiss with prejudice the plaintiffs' Thirteenth Amendment claim. I also dismiss with prejudice the TVPRA claim as to plaintiffs Angela Williams and Jane Doe #2.

I FURTHER ORDER that the Sapphire Club's (SHAC, LLC and SHAC MT, LLC's) motion to dismiss (ECF No. 133) is GRANTED in part. I dismiss with prejudice the plaintiffs' Thirteenth Amendment claim. I also dismiss with prejudice the TVPRA claim as to plaintiffs Angela Williams and Jane Doe #1.

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I FURTHER ORDER that defendant Clark County's motion to strike (ECF No. 164) is DENIED as moot.

I FURTHER ORDER that Russell G. Greer's motion to intervene (ECF No. 105) is DENIED.

I FURTHER ORDER that the remaining defendants may file motions to sever within 30 days of this order if they believe it is appropriate.
Williams v. Sisolak (D. Nev. 2022)

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