In State v. Rich, 132 N.C. App. 440, 512 S.E.2d 441 (1999), aff'd, 351 N.C. 386, 527 S.E.2d 299 (2000), our Court characterized the Wilkerson description as a list of "examples, any one of which may provide the malice necessary to convict a defendant of second-degree murder." Rich, 132 N.C. App. at 446, 512 S.E.2d at 446 (upholding jury instructions permitting malice to be found if any one descriptive phrase in Wilkerson applied to the defendant). On appeal to our Supreme Court, the defendant in Rich argued "if this Court allows the six traditional descriptive words and phrases defining malice to be read in the disjunctive, then it is possible for a jury to convict a defendant of second-degree murder based only on a finding of 'recklessness of consequences.'" State v. Rich, 351 N.C. 386, 527 S.E.2d 299, 303 (2000). According to the defendant, "this would effectively lower the culpability level required to convict a defendant of second-degree murder since 'recklessness of the consequences' is a level of culpability usually associated with negligence." Id. Our Supreme Court in Rich disagreed, noting that "the distinction between 'recklessness' indicative of murder and 'recklessness' associated with manslaughter 'is one of degree rather than kind.'" Id. The Rich Court stated that "because the trial court's instructions, in their entirety, conveyed the level of recklessness required for second-degree murder, we cannot conclude that the jury could have confused such a high degree of recklessness with mere culpable negligence." Id.