United States v. Steven Baker, 496 F. App'x 201

Baker was convicted by a jury of three bank robberies and three firearm enhancements under 18 U.S.C. § 924(c).
The district court sentenced Baker to 87 months for robberies and 57 years for firearms offenses.
The government sought to prove motive via foreclosure notices Baker received before the robberies, but those were excluded as irrelevant and prejudicial.
During trial, the government admitted post-robbery cash-deposit evidence; Baker attempted to cross-examine about other deposits, which the court limited.
Baker challenged several trial rulings, including cross-examination limits, jury instructions on witness availability, and the admissibility of a computer-mapped exhibit, as well as his sentence.
At sentencing, the court applied the mandatory minimum for § 924(c) and placed substantial weight on the Guidelines range, with limited variance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether cross-examination limits violated Baker's Sixth Amendment rights	Baker asserts error from restricting pre-robbery financials.	Baker argues cross-examination was improperly curtailed to mislead the jury.	No reversible error; harmless.
Whether the jury instruction on witness availability was improper	Baker claims the court erred by not treating the case agent as unavailable.	Baker failed to comply with 28 C.F.R. § 16.23(c); instruction was proper.	Instruction not in error.
Whether admission of computer-mapping Exhibit 200 required expert testimony	Gillen's mapping testimony required specialized knowledge.	No error; testimony was non-expert and widely understood.	No plain error; admissible.
Whether the sentence is substantively unreasonable given § 3553(a) factors	Baker seeks avoidance of heavy reliance on Guideline range and disparity with Clayton.	District Court appropriately weighed factors and applied mandatory minimum; disparity not dispositive.	No reversible error; sentence affirmed.

United States v. Frazier, 469 F.3d 85 (3d Cir. 2006) (jury instruction on witness availability not arbitrary or unreasonable)
Donlin v. Philips Lighting North America Corp., 581 F.3d 73 (3d Cir. 2009) (lay witness with particularized knowledge may testify on non-technical matters)
United States v. Tomko, 562 F.3d 558 (3d Cir. 2009) (abuse-of-discretion review for sentencing under 18 U.S.C. § 3553(a))