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

Pornhub Awards Fiesta: A Night of Music, Dancing and Camaraderie

The eighth annual Pornhub Awards transformed Los Candiles Night Club in Glassell Park into a celebration of glamour, glitter, fashion and fame Wednesday night, as performers, creators and industry insiders toasted the year’s winners and danced late into the night while Diplo and Midnight Mary kept the party pulsing from behind the decks.

Carmen Valentina Stars in Latest From Elegant Angel

Carmen Valentina stars with reigning and three-time XMAs Male Performer of the Year Vince Karter in the latest release from Elegant Angel, titled "The Cure for Priapism."

Ukrainian Parliament Rejects Porn Decriminalization Bill

The Verkhovna Rada, Ukraine’s parliament, on Thursday voted against passage of a bill that would have decriminalized the creation and distribution of pornography in that country — an activity that currently carries a prison sentence of three to five years.

Cherie DeVille Leads New Gangbang From Brazzers

Cherie DeVille stars in a new gangbang from Brazzers, titled “Cherie’s Pool Party Parfait.”

Ivy Ireland Fronts Latest From Bellesa Plus

Ivy Ireland stars with Small Hands in the latest release from Bellesa Plus, titled “The Breakup.”

FSC Launches Pride Fundraising Drive

The Free Speech Coalition (FSC) has launched its Pride Fundraising Drive to support its efforts on behalf of the LGBTQ+ community.

Cultpix Debuts AI-Generated Vintage Adult Films at Cannes

At this year’s Cannes Film Festival, B-movie streaming service Cultpix debuted a collection of AI-generated short films drawn from erotic magazine photo spreads published 50 years ago.

Ofcom Fines Youngtek Solutions $800K for AV Noncompliance

U.K. media regulator Ofcom on Wednesday imposed fines totaling 600,000 pounds (more than $800,000) against adult site operator Youngtek Solutions for failing to implement age checks and respond to information requests as required for compliance with the Online Safety Act.

Anna Kolba Makes Her Evil Angel Debut

Anna Kolba has made her debut for Evil Angel alongside director Richard Mann.

Victoria Grant, Dillon Diaz Topline 'TS Lessons' From TransSensual

Victoria Grant and Dillon Diaz headline "TS Lessons," from Mile High Media studio imprint TransSensual.

Show More