Stanley Uchenna Nwoke v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedOctober 28, 2025
Docket0831244
StatusUnpublished

This text of Stanley Uchenna Nwoke v. Commonwealth of Virginia (Stanley Uchenna Nwoke 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
Stanley Uchenna Nwoke v. Commonwealth of Virginia, (Va. Ct. App. 2025).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges O’Brien, Causey and Bernhard UNPUBLISHED

STANLEY UCHENNA NWOKE MEMORANDUM OPINION* BY v. Record No. 0831-24-4 JUDGE DORIS HENDERSON CAUSEY OCTOBER 28, 2025 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF PRINCE WILLIAM COUNTY Robert P. Coleman, Judge

(Danielle S. Brown; Danielle S. Brown Law, PLLC, on brief), for appellant.

(Jason S. Miyares, Attorney General; Allison M. Mentch, Assistant Attorney General, on brief), for appellee.

Following a jury trial, the trial court convicted Stanley Uchenna Nwoke of four counts of

grand larceny, four counts of larceny with intent to sell, two counts of obtaining money by false

pretenses, and one count of petit larceny. By final order dated May 9, 2024, the trial court

sentenced Nwoke to 29 years of incarceration, with 27 years and 6 months suspended, for an active

sentence of a year and a half. On appeal, Nwoke’s assignments of error fall into two categories: the

trial court’s denial of Nwoke’s presentation of a defense, and whether charges should be

misdemeanors or felonies. Nwoke’s contention that he was denied the presentation of a defense

relies primarily on challenging several of the trial court’s evidentiary rulings and the court’s

* This opinion is not designated for publication. See Code § 17.1-413(A). rejection of proffered jury instructions. We find no reversible error in the trial court’s rulings and

affirm the judgment. 1

BACKGROUND2

Between June 2020 and February 2021, Nwoke worked for Visiting Angels and Brightstar

as a home health aide assisting elderly clients. During that time, Nwoke admittedly stole jewelry

and other items from his clients’ homes and sold the items to pawn shops, accumulating over

$66,000.

I. Pre-trial Proceedings

Following a pre-trial conference, the trial court entered an order stating that discovery

was complete. Nwoke agreed. Later, Nwoke filed a motion requesting that his family members

in Nigeria and the United Kingdom be permitted to testify remotely at trial, because his family

members were unable to travel to the United States due to financial constraints. He also filed a

motion to dismiss, arguing that he committed the thefts “pursuant to a single larcenous impulse.”

He reasoned that he should have been charged with only one count of larceny and one count of

obtaining money by false pretenses. Nwoke also filed a memorandum stating that he intended to

rely on a duress defense at trial. He explained that his brother had been kidnapped in Nigeria

and held for ransom and that he committed the thefts in order to raise the ransom money. The

1 Having examined the briefs and record in this case, the panel unanimously agrees that oral argument is unnecessary because “the facts and legal arguments are adequately presented in the briefs and record, and the decisional process would not be significantly aided by oral argument.” Code § 17.1 403(ii)(c); Rule 5A:27(c). 2 “On appeal, we review the evidence in the ‘light most favorable’ to the Commonwealth.” Clanton v. Commonwealth, 53 Va. App. 561, 564 (2009) (en banc) (quoting Commonwealth v. Hudson, 265 Va. 505, 514 (2003)). “This well-settled principle of appellate review ‘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.”’” Wandemberg v. Commonwealth, 70 Va. App. 124, 133 (2019) (quoting Camp v. Commonwealth, 68 Va. App. 694, 698 (2018)). -2- Commonwealth filed a motion in limine to prohibit Nwoke from raising the duress defense at

trial because he failed to satisfy all the elements of the defense.

In September 2023, the trial court heard argument on the motions. The trial court denied

Nwoke’s motion to dismiss, holding that the single impulse doctrine was “not appropriate” in

this case, finding that “it’s a significant stretch to say that [Nwoke] was acting under a single

impulse for eight months [when he committed a] string of larcenies.” The trial court held that it

would wait until trial to rule on the duress defense issue because it was so close to the scheduled

trial. The trial court, however, prohibited defense counsel from bringing up the issue of duress

during voir dire. The court also denied Nwoke’s motion to permit remote testimony from his

witnesses. The trial court held that “WebEx is inherently unreliable” and the court would have

“absolutely no ability to know whether or not these witnesses are being coached.”

II. Trial

A. The Proffer

Before voir dire, the trial court instructed Nwoke to proffer the anticipated duress-related

testimony. Nwoke proffered that his brother was kidnapped, the kidnappers threatened to kill his

brother unless they received $250,000, and Nwoke sent the money he received from the stolen

jewelry to Nigeria to pay his brother’s ransom. The trial court then reconsidered its prior ruling

and permitted Nwoke to discuss the issue of the duress defense during voir dire and opening

statements. The court cautioned Nwoke that if he did not establish a prima facie case for duress,

the court would not only “be required to strike that defense and not allow the duress instruction,

but [the court] may therefore be required to provide a curative instruction as well which tells the

jury to essentially as a matter of law disregard any testimony that they’ve heard as to that duress

defense.” Nwoke agreed. Nwoke proffered statements from his family members describing

their anticipated testimony, had they been permitted to testify remotely. The trial court received

-3- the statements from the family members which stated that Nwoke’s brother was kidnapped and

held for ransom. During voir dire, defense counsel stated that Nwoke planned to present

evidence that he acted out of duress. In opening statements, defense counsel described the

kidnapping and argued that Nwoke committed the thefts “out of desperation to try to save his

brother.”

B. The Testimony

Robert Enzer testified that he hired Visiting Angels to help provide care for his late father

in July or August 2020. Enzer later discovered that his father’s and mother’s watches were

missing. Enzer testified that two of the items on the list were his parents’ watches. Enzer further

testified that his father purchased his watch during a family vacation to Switzerland in 1977 and

when he last saw the watch in 2000, it “was in good shape.”

Patricia Stephan testified that she hired Bright Star to help provide care for her late father

in October 2020. Stephan later noticed that four of her father’s rings were missing, specifically,

a white gold diamond ring, a U.S. Air Force ring, a gold signet ring, and a yellow gold ruby ring.

Stephan testified that she was familiar with her father’s jewelry and that the rings had “little wear

and tear.” The prosecutor showed Stephan an October 27, 2020 pawn shop receipt showing that

Nwoke was paid $2,500 for eight items. The first item on the receipt described four rings, and

Stephan identified one of these rings as her father’s white gold diamond ring. Stephan

recognized the second item on the receipt as her father’s U.S. Air Force ring. The seventh item

on the receipt described two rings, and Stephan identified one of these rings as her father’s

yellow gold signet ring.

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