Supreme Court

23-0202 - In re Jane Doe Cases 

In re Jane Doe Cases

  • Case number: 23-0202
  • Legal category: Procedure-Pretrial
  • Subtype: Multidistrict Litigation
  • Set for oral argument: October 1, 2024

Case Summary

This mandamus arises out of the “tag-along” transfer of the underlying lawsuit to an MDL involving other sex-trafficking cases. The issue in this case is whether the MDL panel erred by refusing to remand the case, thereby allowing it to remain in the MDL.

In the underlying case, Jane Doe alleges that she was a victim of sex trafficking. She contends that another user befriended her on Facebook and sent her messages convincing her to meet in person, after which she was forced into sex with several others at a hotel owned by Texas Pearl. In 2018, Doe sued Facebook and Texas Pearl, alleging they both had roles in facilitating her trafficking. In 2019, the MDL panel transferred seven other cases involving sex trafficking allegations to an MDL pretrial court. In 2022, Texas Pearl filed a Notice of Transfer of Tag-Along Case to move the underlying case into the MDL, asserting that Doe’s claims are closely related to the MDL cases because those cases also involve sex-trafficking allegations against hotels. Facebook responded with a Motion to Remand Improper Tag-Along Transfer, arguing the case should be remanded back to the previous trial court.

The MDL pretrial court denied Facebook’s motion to remand. The MDL panel denied Facebook’s motion for rehearing. Facebook sought mandamus relief in the Supreme Court, arguing the underlying case is not related to those in the sex-trafficking MDL, and the inclusion of the case in the MDL will not improve convenience or efficiency.

The Supreme Court set Facebook’s mandamus petition for oral argument.

 

Case summaries are created by the Court's staff attorneys and law clerks and do not constitute the Court’s official descriptions or statements. Readers are encouraged to review the Court’s official opinions for specifics regarding each case. Links to the full case documents are included above.