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Fifth Circuit Revives Texas Law Restricting 'Sexually Oriented Performances,' Allows Enforcement During Lawsuit

The panel vacated the injunction to require reconsideration under the Supreme Court’s Moody v. NetChoice standard.

Overview

  • The appeals court limited standing to a single plaintiff, San Antonio–based 360 Queen Entertainment, and dismissed other plaintiffs for lack of injury.
  • Judges said most challengers failed to show their events are arguably covered by the statute because the trial record did not establish performances that are erotic.
  • The ruling lifts the prior block, permitting Texas to enforce criminal restrictions related to minors and civil penalties for venues while the case proceeds.
  • Judge James L. Dennis dissented in part, criticizing the majority for overlooking legislative statements framing the measure as a drag ban and for First Amendment missteps.
  • The decision reverses a 2023 ruling by a Houston federal judge that struck down S.B. 12, sending the case back under the stricter Moody facial-challenge test.