United States v. Baker, 349 F. Supp. 3d 1113

Defendant Adonis Baker indicted on sex‑trafficking and related counts (including offenses under 18 U.S.C. §§ 1591 and 2423) involving multiple adult victims and at least one minor; Superseding Indictment later expanded charges.
Government evidence (victim interviews, Backpage advertisements, hotel records, phone data) alleged use of force, threats, drugs, firearms, interstate transportation, and that some victims were too fearful to cooperate; one victim alleged physical violence and a juvenile was allegedly transported across state lines.
Baker has prior convictions (theft, robbery, drug offense), probation violations, an outstanding misdemeanor warrant in Texas, unemployment since 2013, and family ties outside New Mexico (Alabama); some victims remain unlocated.
Magistrate Judge Fashing ordered Baker detained pending trial, finding a rebuttable presumption under 18 U.S.C. § 3142(e)(3) and that the government met its burdens (danger by clear‑and‑convincing evidence; flight risk by preponderance).
Baker moved for release (proposed third‑party custodians and residency at a halfway house); district court conducted de novo review, held a hearing, and affirmed the detention orders.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the § 3142(e)(3) presumption of detention applies	Government: Indictment charges offenses involving a minor under §§ 1591/2423, triggering the rebuttable presumption	Baker: Concedes presumption exists but seeks to rebut it with family custodianship and limited criminal history	Held: Presumption applies (grand jury indictment provides probable cause)
Whether Baker rebutted the presumption	Baker: Offered evidence of minimal criminal history, family custodians, prior employment, and some victims saying they were not afraid	Government: Information was known earlier and is insufficient; additional facts (associate contacted victim) support risk	Held: Baker met the light burden of production but did not prevail on ultimate issue
Whether Baker is a flight risk	Government: Severe potential sentence, weak New Mexico ties, prior failures to appear and probation violations, strong evidence against him	Baker: Proposed halfway house supervision and monitoring	Held: By a preponderance of the evidence Baker is a flight risk; no conditions will reasonably assure appearance
Whether Baker is dangerous to the community/witnesses	Government: Victim accounts of violence, firearms, interstate trafficking, and post‑indictment attempted contact with a victim	Baker: Points to some victim statements minimizing fear; disputes some allegations	Held: By clear‑and‑convincing evidence Baker is a danger; detention affirmed

Estelle v. Williams, 425 U.S. 501 (1976) (articulating the presumption of innocence as a component of a fair trial)
Coffin v. United States, 156 U.S. 432 (1895) (historical source for presumption of innocence)
In re Winship, 397 U.S. 358 (1970) (due process requires proof beyond reasonable doubt for conviction)
United States v. Cisneros, 328 F.3d 610 (10th Cir. 2003) (government bears burden to prove flight by preponderance and dangerousness by clear-and-convincing evidence at detention hearing)
United States v. Silva, 7 F.3d 1046 (10th Cir. 1993) (grand jury indictment suffices to establish probable cause to trigger § 3142(e) presumption)
United States v. Stricklin, 932 F.2d 1353 (10th Cir. 1991) (presumption shifts burden of production to defendant but remains a factor in ultimate detention decision)
United States v. Mercedes, 254 F.3d 433 (2d Cir. 2001) (clarifying burdens on detention issues)
United States v. Williams, 753 F.2d 329 (4th Cir. 1985) (detaining particularly dangerous defendants pending trial may be appropriate)
United States v. Bell, 761 F.3d 900 (8th Cir. 2014) (discussion of victims’ reluctance to report because of threats or fear)