USCA4 Appeal: 25-4096 Doc: 35 Filed: 12/23/2025 Pg: 1 of 5

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 25-4096

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

ADJOH DORCAS MANOU EPSE ASSOKO,

Defendant - Appellant.

Appeal from the United States District Court for the Eastern District of Virginia, at Alexandria. Michael Stefan Nachmanoff, District Judge. (1:24-cr-00172-MSN-1)

Submitted: November 26, 2025 Decided: December 23, 2025

Before NIEMEYER, AGEE, and BERNER, Circuit Judges.

Affirmed by unpublished per curiam opinion.

ON BRIEF: Geremy C. Kamens, Federal Public Defender, Salvatore M. Mancina, Assistant Federal Public Defender, Nathaniel C. Wenstrup, Assistant Federal Public Defender, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Alexandria, Virginia, for Appellant. Erik S. Siebert, United States Attorney, Meredith J. Edwards, Assistant United States Attorney, Daniel J. Honold, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Alexandria, Virginia, for Appellee.

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PER CURIAM:

A federal jury convicted Adjoh Dorcas Manou Epse Assoko of international

parental kidnapping, in violation of

(a). The district court sentenced

Assoko to a term of imprisonment of 12 months and one day followed by one year of

supervised release. Assoko appeals, challenging the court’s jury instruction regarding the

requisite intent to obstruct the lawful exercise of her husband’s parental rights and the

sufficiency of the evidence supporting her conviction. We affirm.

Assoko first challenges the district court’s decision refusing her proposed jury

instruction regarding the intent required to obstruct the lawful exercise of her husband’s

parental rights. We review the adequacy of the court’s jury instructions for abuse of

discretion. United States v. Sonmez,

(4th Cir. 2015). In order to establish

that a district court abused its discretion in rejecting proposed jury instructions, a defendant

“must demonstrate that her proposed instructions (1) were correct, (2) were not

substantially covered by the charge that the district court actually gave to the jury, and (3)

involved some point so important that the failure to give the instructions seriously impaired

the defendant’s defense.”

(citation modified).

Assoko argues that her proposed jury instruction, which would have required the

jury to find that the intent to obstruct her husband’s parental rights was a “significant

purpose” motivating her decision to move to Côte d’Ivoire, was correct. The district court

declined to give Assoko’s proposed jury instruction and instead instructed the jury that,

“[t]o find that the defendant acted with the intent to obstruct the lawful exercise of parental

rights, you must find that the defendant acted deliberately with the purpose of interfering

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with the parental rights of [her husband].” (J.A. 485). ∗ We conclude that, by instructing

the jury in this manner, the district court “substantially covered” the content of Assoko’s

proposed instruction that the Government was required to prove that Assoko intended by

her actions to interfere with her husband’s parental rights. See Sonmez,

.

Therefore, we hold that the district court did not abuse its discretion in refusing Assoko’s

“significant purpose” instruction.

Assoko also argues that the district court erred in denying her Fed. R. Crim. P. 29

motion for a judgment of acquittal based on insufficient evidence of international parental

kidnapping. “We review the denial of a motion for judgment of acquittal de novo.” United

States v. Savage,

(4th Cir. 2018). In assessing the sufficiency of the

evidence, we determine whether there is substantial evidence to support the conviction

when viewed in the light most favorable to the government.

“Substantial evidence is

evidence that a reasonable finder of fact could accept as adequate and sufficient to support

a conclusion of a defendant’s guilt beyond a reasonable doubt.” United States v.

Rodriguez-Soriano,

(4th Cir. 2019) (citation modified). In making this

determination, we may not resolve conflicts in the evidence or evaluate witness credibility.

Savage,

. “A defendant who brings a sufficiency challenge bears a heavy

burden, as appellate reversal on grounds of insufficient evidence is confined to cases where

the prosecution’s failure is clear.”

(citation modified).

∗ “J.A.” refers to the joint appendix filed by the parties in this appeal.

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The international parental kidnapping statute provides that

[w]hoever removes a child from the United States, or attempts to do so, or retains a child (who has been in the United States) outside the United States with intent to obstruct the lawful exercise of parental rights shall be fined under this title or imprisoned not more than 3 years, or both.

(a). Assoko argues that, in taking their daughter to Côte d’Ivoire, Assoko

reasonably believed that her husband would be joining them because they had been

planning to move back to Côte d’Ivoire and because his United States visa was dependent

on hers. She further argues that her husband’s testimony at trial was not credible and that

she left the United States for a job rather than to obstruct his parental rights.

We conclude that sufficient evidence existed for the jury to discredit Assoko’s stated

reasons for relocating to Côte d’Ivoire. After arriving in Côte d’Ivoire with her daughter

without notifying her husband or the state court overseeing custody proceedings, Assoko

remotely attended a custody hearing where her husband was granted temporary primary

custody of their daughter. At the hearing, Assoko stated that she was unable to afford to

buy a plane ticket back to the United States. The next month, she arrived in the United

States but left her daughter in Côte d’Ivoire, despite not having custody over her. Assoko

further misled agents from the Federal Bureau of Investigation regarding her daughter’s

American citizenship, and text messages between Assoko and her husband displayed her

desire to restrict his visitation rights. Upon review of the record, we conclude that

substantial evidence supports Assoko’s conviction.

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Accordingly, we affirm the judgment. We dispense with oral argument because the

facts and legal contentions are adequately presented in the materials before this court and

argument would not aid the decisional process.

AFFIRMED

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