Betts v. Sixty Lower East Side, LLC — 2d Cir. (Nov 9, 2026)

The Second Circuit reviews a ruling against hotel companies in a guest’s negligence lawsuit. Betts called the front desk for an in-room massage, and the hotel arranged an outside therapist. She says he sexually assaulted her during the appointment. He held a professional license, but his New York registration had expired. A federal judge found the hotel companies liable without a trial on that issue. The judge treated the hotel’s violation of New York’s massage-services law as negligence in itself, and found a legal causal link to her injuries. The companies will contest how the statute applies, whether it establishes negligence, and whether the violation caused the assault. Betts will defend the ruling as enforcing protections for massage clients. Betts v. Sixty Lower East Side, LLC (No. 25-2108) — U.S. Court of Appeals for the Second Circuit, argued November 9, 2026. Sources: Official Second Circuit oral argument — November 9, 2026: https://ww3.ca2.uscourts.gov/audio/25-2108.mp3 District-court memorandum and order — Betts, Doc. 75, August 21, 2023: https://cases.justia.com/federal/district-courts/new-york/nysdce/1:2020cv04772/539059/75/0.pdf?ts=1692718822