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

New Kickstarter Rules Ban Fundraising for Adult Content, Products

Crowdfunding platform Kickstarter has posted new “Mature Content” rules banning projects that involve adult content and sextech.

Lucy Mochi Performs 1st Studio Anal for Brazzers

Lucy Mochi performs her first studio anal scene opposite Scott Nails in the latest Brazzers release, "Fresh and Ready for Anal."

WebGroup Czech Republic Settles Florida AV Suit, Will Pay $1.2 Million

WebGroup Czech Republic (WGCZ), the parent company of XVideos, XNXX, BangBros and GirlsGoneWild, has settled a lawsuit filed by the state of Florida over those sites’ alleged failure to age-verify Florida users before allowing access to adult content.

Blake Blossom, Romi Rain & Ophelia Fae Star in Latest From Girlsway

Blake Blossom, Romi Rain, and Ophelia Fae star in the latest release from Girlsway, titled "Downward Temptation."

AEBN Publishes Popular Searches for March, April

AEBN has published the top search terms for March and April from its straight and gay theaters in all 50 states and the District of Columbia.

Tiffani Time Fronts Latest From Kink.com

Tiffani Time stars with director John Paul “The Pope” in the latest installment of Kink.com’s "Device Bondage" series, titled “Taken Down a Notch.”

Eris Jolie, Athena Parisi Star in Latest From TGirls.Porn

Eris Jolie and Athena Parisi star in the latest release from Grooby paysite TGirls.Porn, titled "Pool Day Date."

Leilani Li, Olivia Jay Lead Latest From TransAngels

Leilani Li and Olivia Jay star with King Noire in the latest release from TransAngels, titled "Deep Dive."

Ofcom Investigates Two Sites Over Possible AV Violations

U.K. media regulator Ofcom on Wednesday launched investigations into two adult sites as part of its age assurance enforcement program under the Online Safety Act (OSA).

Cami Strella, River Lynn Front Latest From New Sensations

Cami Strella and River Lynn star in the latest release from New Sensations.

Show More