6th Circuit Grants Rehearing in 2257 Case

CINCINNATI — In an order issued today, the 6th Circuit U.S. Court of Appeals has granted the government’s request for an en banc (full court) rehearing of the 6th Circuit panel decision that ruled 2257 unconstitutional in October of last year.

The government filed its request for an en banc rehearing in January, arguing that the 6th Circuit panel had erred in its reading of the statute.

“Construing the age verification and recordkeeping provisions to apply to private couples who create explicit images of themselves for personal use in their own homes, the panel invalidated the act on the ground that it is so over-inclusive that it can no longer constitutionally be applied even to producers of commercial images for the pornography industry,” the Justice Dept. stated in its January petition.

Free Speech Coalition Chairman Jeffrey Douglas told XBIZ that the court’s decision to grant the rehearing was “disappointing, but by no means surprising.”

“Any time a federal statute is struck down, there is a tendency for the court to want to hear the issue en banc,” Douglas said. “The reasoning of the panel majority was excellent, however, and I’m reasonably optimistic that it will stand.”

Adult industry attorney Larry Walters was less optimistic about the prospects of the panel’s decision being upheld, however.

“The granting of rehearing en banc does not bode well for the viability of the decision under review,” Walters said. “I suspect that one or more judges voted to rehear the case in order to change the decision and ultimately uphold section 2257. It all depends on how many other judges go along with that approach, however. Only time will tell.”

Attorney JD Obenberger concurred with Walters, and said that the fact that the 6th Circuit had granted the rehearing was “certainly not good news for the adult entertainment industry.”

“The real issue dealt with by the panel was whether 2257 could be constitutional if it was construed to apply only to commercial activity,” Obenberger said, adding that while the statute does not expressly state that it is limited to commercially distribute material, 2257 does contain certain “clues” that the intent of Congress was to limit 2257 to commercial activity.

“2257 requires that your records be stored at your ‘primary place of business,’” Obenberger noted “Well, only businesses have a ‘primary place of business,’ so that’s one clue right there.”

Obenberger said that while voting to grant the rehearing does not indicate that the other judges from the 6th Circuit necessarily feel that the panel’s decision was wrong, but indicates that they feel there’s a significant enough chance that the panel erred that the full circuit should hear the arguments for itself.

“My opinion on this has not changed — which is that portions of 2257 probably are unconstitutional, but I think there are also substantial portions that are not,” Obenberger said. “That’s why I think this rehearing will result in the case being remanded [for trial].”

Related:  

Copyright © 2026 Adnet Media. All Rights Reserved. XBIZ is a trademark of Adnet Media.
Reproduction in whole or in part in any form or medium without express written permission is prohibited.

More News

Segpay Partners With Corey Silverstein for Legal Services

Segpay has partnered with adult industry attorney Corey D. Silverstein for specialized legal compliance and policy support for its merchant network.

AEBN Reveals Kasey Kei as Top Trans Star for Q2 of 2026

AEBN has named its top trans stars for the second quarter of 2026, with Kasey Kei landing atop the leaderboard.

Victoria Grant Stars in Latest From TransAngels

Victoria Grant stars with Daniel Gainsbrook in the latest release from TransAngels, titled "Seduced by the Belly Dancer."

Missouri Governor Signs Bill Making AV Regulations State Law

Missouri Governor Mike Kehoe signed a bill into law on Thursday requiring adult websites to age-verify users in the state, finalizing a legislative “stamp of approval” for AV rules after Missouri’s attorney general unilaterally imposed similar regulations last year.

Utherverse Launches 'Adult Game Fest' Virtual Convention

Virtual reality and metaverse technology company Utherverse is launching its inaugural Adult Game Fest convention and trade show, taking place Sept. 24-26.

Ameena Green Fronts Latest From Bellesa Plus

Ameena Green stars with multi-XMAs winner Alex Jones in a release from Bellesa Plus, titled “The Tailor.”

Ofcom Fines Fapello $845,000 for AV Noncompliance

U.K. media regulator Ofcom on Thursday imposed a fine of 630,000 pounds (about $845,000) against adult website fapello.com for failing to comply with provisions of the Online Safety Act.

Hazel Heart, Rissa May & Isabella Jules Lead Latest From Girlsway

Hazel Heart stars with Rissa May and Isabella Jules in the latest release from Girlsway, titled “No Boys, No Problem!”

Dallas Rea Makes Her TeamSkeet Debut

Dallas Rea has made her debut for TeamSkeet alongside Chris Sterling.

On the Set: Cherry Kiss Caps a Decade With 'Cherry on Top'

Cherry Kiss is dabbing sweat off Seth Gamble’s forehead as he hovers over Ella Reese, a black makeup bag slung across her chest.

Show More