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

Venus Berlin Joins ASACP as Media Sponsor

Venus Berlin has signed on as an in-kind media sponsor for the Association of Sites Advocating Child Protection (ASACP).

Ava Holt Stars in Latest From TGirls.xxx

Ava Holt stars with Chris Epic in the latest release from Grooby paysite TGirls.xxx, titled "Happy Wife, Happy Life."

XBIZ Miami's Host Hotel Sold Out; Additional Hotel Added

Guest rooms at XBIZ Miami’s exclusive conference venue, Goodtime Hotel in South Beach, are now completely sold out.

Brooke Tilli, Mick Blue Star in Latest From Brazzers

Brooke Tilli stars with multi-XMAs winner Mick Blue in the latest release from Brazzers, titled "En Pointe Pounding."

Reptyle to Debut Cross-Site Release 'Polar Opposites'

Reptyle will premiere its latest cross-site release, "Polar Opposites," across all six of its imprints starting Saturday.

Penthouse Wins Trademark Infringement Case Against Fraudulent Domain

The World Intellectual Property Organization (WIPO) has ruled in favor of Penthouse World Media in a case against a website using an infringing domain.

Kyaa Chimera, Renee Rose Front Latest From Family Strokes

Kyaa Chimera and Renee Rose star with multi-XMAs winner Tommy Gunn in the latest release from Family Stroke.

Lilly Bell Headlines 'Maison Close' From Dorcel

2025 XMAs Girl/Girl Performer of the Year Lilly Bell stars in "Maison Close," the latest feature from Dorcel.

'Collective Corruption' Relaunches Through PAYSITE

Fetish and BDSM membership site Collective Corruption has relaunched through PAYSITE.

Milena Ray Is Hustler's 'Cover Honey' for May

Milena Ray is the Cover Honey for the May issue of Hustler Magazine and appears in a 14-page centerfold spread shot by Davide Esposito.

Show More