--- title: "United States v. Gammarano" citation: "321 F.3d 311 (2d Cir. 2003)" authority_id: "AUTH-CA2-GAMMARANO-321-F3D-311" authority_type: "case" jurisdiction: "federal_second_circuit" precedential_status: "binding_in_ca2" url: "https://jason93.com/legal/federal-process/authorities/AUTH-CA2-GAMMARANO-321-F3D-311/" legal_review: "2026-08-25" links_checked: "2026-10-15" links_available: 1 links_checked_count: 1 license: "CC BY 4.0" --- # United States v. Gammarano ## Holdings used - A court deciding modification or early termination must consider the listed statutory factors, but need not make separate findings on each when the statement and record show consideration. ## Material limitation Binding only in the Second Circuit and only for the bounded procedural postures in the linked claims. Published precedential full opinion reviewed from a public reporter reproduction after no stable historical official opinion file was located. No fixed explanation length, merits presumption, or changed-circumstances rule is inferred. A comprehensive commercial citator was not run. ## Official source and pinpoints 321 F.3d 311 (2d Cir. 2003), 321 F.3d 315–16: ## Linked claims - `CLM-CIR2-005` ## Used in - [Second Circuit Overlay](https://jason93.com/legal/federal-process/modules/95-circuit-overlays/second-circuit.md)