3rd Circuit Won't Rehear 2257 Case

3rd Circuit Won't Rehear 2257 Case

PHILADELPHIA — The 3rd U.S. Circuit Court of Appeals on Thursday denied the Justice Department’s petition for a rehearing over a three-judge panel’s decision over 18 U.S.C. §§2257 and 2257A, the federal statutes that govern performer record-keeping for sexually explicit content.  

“The petition for rehearing filed by appellee in the above-entitled case having been submitted to the judges who participated in the decision of this court and to all the other available circuit judges of the circuit in regular active service, and no judge who concurred in the decision having asked for rehearing, and a majority of the judges of the circuit in regular service not having voted for rehearing, the petition for rehearing by the panel and the Court en banc, is denied,” a panel for the 3rd Circuit decided today.

One jurist, Judge Thomas Vanaskie, was the only holdout of the 13 judges deciding the petition. Vanaskie noted he would grant rehearing by the court en banc.

The 3rd Circuit ruling sends the case back to U.S. District Judge Michael Baylson’s courtroom in Philadelphia for reconsideration. Or, for the matter, an appeal to the U.S. Supreme Court by the Justice Department.

Adult entertainment trade group the Free Speech Coalition and various performers and industry stakeholders sued the government over the laws, holding that the inspection provisions of the statutes are facially unconstitutional.

The initial win for the plaintiffs in June, and consequently all adult entertainment producers, was hailed as one of the greatest adult industry victories in decades.

In June, the 3rd Circuit vacated and remanded a lower court’s July 2013 ruling that held that performer record-keeping for adult entertainment producers are constitutional.

The 3rd Circuit, in the judgment, held that the inspection provisions of the statutes are facially unconstitutional under the 4th Amendment.

With the ruling, most of 2257 became unenforceable due to its violation of the 4th Amendment on unreasonable seizures. The case now would go back to the trial court over the case’s 1st Amendment claims.

On Thursday, FSC attorney Michael J. Murray, who litigated the case, called the 3rd Circuit’s decision “an exciting victory for the adult industry.”

“But it is not over yet,” Murray told XBIZ. “I think there a good chance that they will take the case to the U.S. Supreme Court. With the Justice Department asking for a review en banc, it sends a signal that they may file a motion to stay its decision. But they would have seven days to do it.”

Murray noted that the Justice Department has up to 90 days to file a petition for writ of certiorari to ask the high court to review the decision.

Industry attorney Lawrence Walters told XBIZ that FSC attorney “Mike Murray’s impressive victory remains in place."

"Unless the government seeks review by the U.S. Supreme Court, the case will be sent back to the trial court for a full determination of the 1st Amendment challenges to the statute, Walters said. "In light of the 3rd Circuit’s binding decision on the 1st Amendment issues, hopes are high that the district court judge will strike down the remainder of the statute and deliver a full victory to the plaintiffs.”

Another industry attorney, Allan B. Gelbard, called the decision by the 3rd Circuit "excellent news."

"Mike Murray is to be commended for his years of effort on this case," Gelbard said.  




View today's ruling

Related:  

Copyright © 2025 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

Vanna Bardot Slithers Into the Spotlight in X3 Magazine

Twice-crowned XMAs Female Performer of the Year Vanna Bardot headlines the latest issue of X3 magazine, the industry’s premier “authenticity first” publication spotlighting the real personalities, passions, and stories behind today’s top stars.

On the Set: Adriana Chechik Returns in Ricky Greenwood's New Dorcel Feature

The walls of the Miami hotel room are painted lilac, with neon pink LED strips lining the corners. There’s a fake white plant, and teal drapes frame the lone window. A packed suitcase lies by the door.

Ana Foxxx, Jade Venus Star in Latest From Transfixed

Ana Foxxx and Jade Venus star in the latest release from Transfixed, titled "Third Date Jitters."

Jasmine Sherni Gets Exorcised in Latest From Brazzers

Jasmine Sherni stars with Luna Star and Scott Nails in the latest scene from Brazzers, titled “The Brazzorcist.”

Elana Bunnz Makes Her WIFEY Debut

Elana Bunnz stars with her husband Don and Prince Yahshua in the latest release from Vixen Media Group studio imprint WIFEY.

'MILFlicious' Launches Through YourPaysitePartner

MILFlicious.com has officially launched through YourPaysitePartner (YPP).

Evil Angel Debuts Pat Myne's 'Jax Slayher For Days 2'

Evil Angel has released director Pat Myne’s new showcase title, “Jax Slayher For Days 2.”

Heaven & Hell Industry Bash Set for Tonight in Hollywood

The annual Heaven & Hell adult industry Halloween party will take place tonight at The Jungle in Hollywood from 9 p.m. to 3 a.m. (PDT).

Op-Ed: The Guardian's XBIZ Amsterdam Podcast Dismisses Creators' Experiences

British newspaper The Guardian’s podcast coverage of XBIZ Amsterdam 2025 purports to investigate the power dynamics of today’s online adult industry. Instead, it ignores creators’ voices, airs tired and outdated preconceptions about the business, and rehashes the unsupported claims of anti-pornography crusaders.

Eva Maxim, BranditScan Launch 'Killer' Promo

Eva Maxim and BranditScan have partnered for the Killer Creator Giveaway promotion.

Show More