Elliot J. Litvak v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedJuly 1, 2025
Docket0411242
StatusUnpublished

This text of Elliot J. Litvak v. Commonwealth of Virginia (Elliot J. Litvak v. Commonwealth of Virginia) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Elliot J. Litvak v. Commonwealth of Virginia, (Va. Ct. App. 2025).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges Fulton, Causey and Lorish UNPUBLISHED

Argued by videoconference

ELLIOT J. LITVAK MEMORANDUM OPINION* BY v. Record No. 0411-24-2 JUDGE DORIS HENDERSON CAUSEY JULY 1, 2025 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF HENRICO COUNTY Rondelle D. Herman, Judge

Wes B. Simon (The Simon Law Firm, on brief), for appellant.

Mason D. Williams, Assistant Attorney General (Jason S. Miyares, Attorney General, on brief), for appellee.

A jury convicted Elliot J. Litvak of both a first offense and a second or subsequent

offense of computer solicitation of a minor in violation of Code § 18.2-374.3(C). The trial court

sentenced Litvak to 70 years of incarceration with all but 15 years suspended. On appeal, Litvak

argues that the trial court erred by denying his request to sever the charges against him and by

allowing an amendment to Jury Instruction 10. Litvak argues that the amendment to Instruction

10 was error because the instructions had already been read to the jury and because the amended

instruction, he argues, advised the jury of an element that was not properly part of the offense

charged. For the following reasons, we affirm the convictions.

* This opinion is not designated for publication. See Code § 17.1-413(A). BACKGROUND1

The offenses

In 2020, Detective Joseph Wechsler of the Henrico County Police Department was a

member of the Internet Crimes Against Children task force. In that role, Detective Wechsler

investigated online crimes against children through a social media platform called “Mocospace.”

Mocospace had a chat function that allowed users to send direct messages to one another.

Detective Wechsler posed as “Kylie-6,” a juvenile, and waited for potential online predators to

send “Kylie” a message. He used photos of a female officer to represent “Kylie.”

On April 15, 2020, Litvak used his Mocospace account2 to send messages to “Kylie-6.”

Litvak told “Kylie” he was “63 and married.” Detective Wechsler replied that “Kylie” was

“almost fifteen.” Litvak responded, “damn you are pretty baby girl.” During the conversation,

Litvak told “Kylie” that he wanted to “make [her] wet” and “take [her] top off and . . . suck [her]

tits.” He also wrote that he would “suck [Kylie’s nipples] and make [her] finger [her]self.”

Litvak told “Kylie” to “rub [her] p***y.”

Trial court proceedings

On September 13, 2021, the grand jury indicted Litvak of electronic solicitation of a

minor in violation of Code § 18.2-374.3(C). The indictment charged the following:

[Litvak] . . . while being over the age of 18 years old, and being at least seven years older than the child, did use a communication

1 “Consistent with the standard of review when a criminal appellant challenges the sufficiency of the evidence, we recite the evidence below ‘in the “light most favorable” to the Commonwealth, the prevailing party in the trial court.’” Hammer v. Commonwealth, 74 Va. App. 225, 231 (2022) (quoting Commonwealth v. Cady, 300 Va. 325, 329 (2021)). This standard “requires us to ‘discard the evidence of the accused in conflict with that of the Commonwealth, and regard as true all the credible evidence favorable to the Commonwealth and all fair inferences to be drawn therefrom.’” Cady, 300 Va. at 329 (quoting Commonwealth v. Perkins, 295 Va. 323, 324 (2018)). 2 Of note, Litvak denied at trial that he had sent the above-referenced messages but admitted that the Mocospace account was his. -2- system for the purposes of soliciting, with lascivious intent, any person he knows or has reason to believe is a child younger than 15 years of age to knowingly and intentionally propose that any such child feel or fondle his own sexual or genital parts or the sexual or genital parts of such person or propose that such person feel or fondle the sexual or genital parts of any such child.

On July 11, 2022, the grand jury also indicted Litvak of a “second or subsequent offense”

under the same Code subsection. The second indictment charged the same actions as the first

and added a sentence reading, “This being a second or subsequent offense.”

Before the start of Litvak’s jury trial, the parties discussed jury instructions. Litvak

objected to a portion of the instruction that corresponded to the second indictment (“Instruction

10”). The instruction required the jury to find that the crime was a “second or subsequent

offense.” He argued that the language was “extremely prejudicial” and would lead the jury to

believe there “must have been a first [offense].” The court overruled the objection, finding that

the second or subsequent language was an element of the offense, and stated that counsel could

address any issues during closing argument. In response, Litvak moved to sever the charges for

separate trials. The court denied the motion and commented that severing the charges would not

resolve Litvak’s concern because the jury instruction at a separate trial would require the same

language.

At the conclusion of all the evidence, the trial court read the instructions to the jury.

Instruction 9 stated in part, “The defendant is charged with the crime of using a computer . . . for

the purpose of soliciting, with lascivious intent, a person he knew, or had reason to believe, was

less than 15 years of age to propose that defendant feel or fondle the sexual or genital parts of

such child.” (Emphases added). Instruction 9 continued, “The Commonwealth must prove

beyond a reasonable doubt . . . [t]hat the defendant used a computer . . . for the purpose of

soliciting ‘Kylie’ to engage in the Defendant feeling or fondling her sexual or genital parts.”

(Emphases added). Instruction 10 read in part, -3- The defendant is charged with the crime of using a computer . . . for the purpose of soliciting, with lascivious intent, a person he knew, or had reason to believe, was less than 15 years of age to propose that such child feel or fondle the sexual or genital parts of defendant, second offense.

(Emphases added). Instruction 10 continued, “The Commonwealth must prove beyond a

reasonable doubt . . . [t]hat the defendant used a computer . . . for the purpose of soliciting, with

lascivious intent, ‘Kylie’ to engage in the feeling or fondling of the sexual or genital parts of the

defendant.” (Emphases added). And it stated that the Commonwealth must prove “[t]hat this is

a second or subsequent offense.”

During the Commonwealth’s closing argument, the Commonwealth noticed an error with

Instruction 10 and requested a brief recess. Outside of the presence of the jury, the

Commonwealth explained that Instruction 10 should have stated that Litvak solicited “Kylie” to

engage in the feeling or fondling of “Kylie’s” own sexual or genital parts, not Litvak’s, because

the evidence was that Litvak told “Kylie” to “masturbate herself.” Litvak objected and argued

that the instruction was already read to the jury and the amendment would cause “confusion.”

The court overruled the objection and stated that the instruction needed to be “presented properly

to the jury.” Litvak then objected to the amendment of Instruction 10 itself, arguing that because

the accusations described in the two charges were different, the language relating to a “second or

subsequent offense” was now not “consistent.” The court overruled Litvak’s second objection

and stated that counsel could address the issue during closing argument.

After the jury reentered the courtroom, the court explained the error and read the

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Scott v. Com.
651 S.E.2d 630 (Supreme Court of Virginia, 2007)
Castle v. Lester
636 S.E.2d 342 (Supreme Court of Virginia, 2006)
Commonwealth v. Minor
591 S.E.2d 61 (Supreme Court of Virginia, 2004)
Alger v. Commonwealth
590 S.E.2d 563 (Supreme Court of Virginia, 2004)
Cook v. Commonwealth
372 S.E.2d 780 (Court of Appeals of Virginia, 1988)
Long v. Commonwealth
456 S.E.2d 138 (Court of Appeals of Virginia, 1995)
Darnell v. Commonwealth
370 S.E.2d 717 (Court of Appeals of Virginia, 1988)
Payne v. Commonwealth
794 S.E.2d 577 (Supreme Court of Virginia, 2016)
Commonwealth v. Perkins (ORDER)
812 S.E.2d 212 (Supreme Court of Virginia, 2018)
Thomas Robert Lienau v. Commonwealth of Virginia
818 S.E.2d 58 (Court of Appeals of Virginia, 2018)
Justin Godfrey Fahringer v. Commonwealth of Virginia
827 S.E.2d 1 (Court of Appeals of Virginia, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Elliot J. Litvak v. Commonwealth of Virginia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/elliot-j-litvak-v-commonwealth-of-virginia-vactapp-2025.