--- title: "United States v. Richter" citation: "510 F.3d 103 (2d Cir. 2007)" authority_id: "AUTH-CA2-RICHTER-510-F3D-103" authority_type: "case" jurisdiction: "federal_second_circuit" precedential_status: "binding_in_ca2" url: "https://jason93.com/legal/federal-process/authorities/AUTH-CA2-RICHTER-510-F3D-103/" legal_review: "2026-08-26" links_checked: "2026-10-15" links_available: 1 links_checked_count: 1 license: "CC BY 4.0" --- # United States v. Richter ## Holdings used - A complete lack of collateral review might support audita querela only if it raised serious constitutional questions; Booker nonretroactivity did not create that circumstance. ## Material limitation Binding only in the Second Circuit and only for the bounded procedural postures in the linked claims. Published per curiam full opinion reviewed from a public court-document reproduction after no stable historical official opinion file was located. Richter does not hold that the writ lies in any actual case and predates Jones v. Hendrix; no post-Jones exception is inferred. A comprehensive commercial citator was not run. ## Official source and pinpoints 510 F.3d 103 (2d Cir. 2007), 510 F.3d 104: ## Linked claims - `CLM-CIR2-006` ## Used in - [Second Circuit Overlay](https://jason93.com/legal/federal-process/modules/95-circuit-overlays/second-circuit.md)