State v. Brichikov

CourtCourt of Appeals of North Carolina
DecidedJanuary 18, 2022
Docket20-660
StatusPublished

This text of State v. Brichikov (State v. Brichikov) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Brichikov, (N.C. Ct. App. 2022).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

2022-NCCOA-33

No. COA20-660

Filed 18 January 2022

Wake County, No. 18 CRS 207577

STATE OF NORTH CAROLINA

v.

MARK BRICHIKOV, Defendant.

Appeal by Defendant from judgment entered 11 December 2019 by Judge

Rebecca W. Holt in Wake County Superior Court. Heard in the Court of Appeals 11

May 2021.

Attorney General Joshua H. Stein, by Special Deputy Attorney General Marc X. Sneed, for the State.

M. Gordon Widenhouse, Jr., for defendant-appellant.

MURPHY, Judge.

¶1 A defendant is entitled to a jury instruction on a lesser included offense when

the evidence, viewed in the light most favorable to the defendant, could support a jury

verdict on that lesser included offense. When there is a reasonable possibility that

the jury would have reached a different result had the trial court given the jury

instruction on a lesser included offense, a defendant suffers prejudice and is entitled

to a new trial.

¶2 Here, the evidence, when viewed in the light most favorable to Defendant, STATE V. BRICHIKOV

Opinion of the Court

entitled him to a jury instruction on the lesser included offense of involuntary

manslaughter. There was a reasonable possibility that a different result would have

been reached had the involuntary manslaughter instruction been given to the jury,

and Defendant is entitled to a new trial.

BACKGROUND

¶3 Defendant Mark Brichikov appeals his second-degree murder conviction in the

death of his wife, Nadia Brichikov. Defendant and Mrs. Brichikov both were regular

drug users. Only two days prior to her death, Mrs. Brichikov suffered a drug

overdose, which resulted in a significant wound to the back of her head and required

medical personnel to use Narcan to reverse the impact of opioids in her system. Mrs.

Brichikov subsequently told Defendant about the overdose and the use of Narcan to

revive her.

¶4 On 21 April 2018, Defendant and Mrs. Brichikov coordinated their meet up at

a motel, and expressed their love for one another and desire to be together multiple

times. Defendant had just left a drug rehabilitation facility, and Mrs. Brichikov had

recently left jail and suffered the overdose the day before. However, Mrs. Brichikov

had been sexually active with at least one individual other than Defendant, and she

was also presently working as a confidential police informant. Defendant and Mrs.

Brichikov met at a motel on the evening of 21 April 2018; during that evening and

the early morning hours of 22 April 2018, Defendant and Mrs. Brichikov exited their STATE V. BRICHIKOV

motel room multiple times, and Defendant appeared to have purchased drugs from a

truck nearby.

¶5 In the early morning hours on 22 April 2018, responding law enforcement

personnel found Mrs. Brichikov deceased in her motel room, with blunt force trauma

to her face, as well as drug paraphernalia and Narcan in the room. Mrs. Brichikov

had cocaine and fentanyl in her system at the time of her death. Responding law

enforcement viewed motel surveillance video, which showed Defendant exiting the

motel room and Mrs. Brichikov lying on the floor of the room. Law enforcement

obtained a warrant and arrested Defendant for murder.

¶6 Defendant was indicted for first-degree murder in the death of Mrs. Brichikov.

At trial, the State presented evidence Defendant assaulted Mrs. Brichikov in the

motel room after they entered the motel room together for the final time in the early

morning of 22 April 2018. During the assault and until she was located by police,

Defendant and Mrs. Brichikov were the only individuals inside the motel room; while

multiple individuals walked by Mrs. Brichikov while she was lying on the ground in

the motel room, they did not enter the room. The State introduced motel video

surveillance, which showed Defendant left the motel room for the final time in the

early morning hours of 22 April 2018, and also showed Mrs. Brichikov assaulted, on

the floor, and moving when Defendant left.

¶7 At trial, the medical examiner called by the State opined that Mrs. Brichikov’s STATE V. BRICHIKOV

death was a “homicide,” due to the presence of blunt force trauma consistent with an

assault as at least a partial cause of the death. The medical examiner called by

Defendant agreed.

¶8 Further, both experts also agreed that Mrs. Brichikov’s significant heart

condition (due to a narrowing of a coronary artery), as well as fentanyl in her system,

contributed to her death, and pointed to all three circumstances–the assault, the

heart condition, and the fentanyl–as contributing factors to her death, or

comorbidities. The State’s expert was not certain whether the removal of any one of

these factors would have prevented Mrs. Brichikov’s death, while Defendant’s expert

testified Mrs. Brichikov would not have died of the facial fractures from the assault

alone. Defendant’s expert also testified that Mrs. Brichikov’s movements when

Defendant left the room appeared to be consistent with a fentanyl overdose, rather

than the assault to her face, and noted Mrs. Brichikov’s airways “were

unobstructed.”1

1We note the experts’ disagreement does not negate Defendant’s criminal responsibility. See State v. Bethea, 167 N.C. App. 215, 222, 605 S.E.2d 173, 179 (2004) (marks and citations omitted) (“To escape responsibility based on an intervening or superseding cause, the defendant must show that the intervening or superseding act was the sole cause of death. An intervening or superseding cause is a cause that so entirely intervenes in or supersedes the operation of the defendant’s negligence that it alone, without his negligence contributing thereto in the slightest degree, produces the injury.”), cert. denied, 362 N.C. 88 (2007); see also State v. Quesinberry, 319 N.C. 228, 233, 354 S.E.2d 446, 449 (1987) (“A person is criminally responsible for a homicide if his act caused or directly contributed to the death of the victim.”). Here, Defendant could still be criminally responsible for Mrs. Brichikov’s death because his assaultive behavior directly contributed to her death. STATE V. BRICHIKOV

¶9 Defendant did not testify during his case in chief, but he admitted under oath

outside the jury’s presence during the charge conference that he assaulted Mrs.

Brichikov and allowed his attorney to admit the same in closing arguments. After

both sides rested, Defendant requested voluntary manslaughter and involuntary

manslaughter jury instructions. During the charge conference, Defendant also

requested a pattern jury instruction for second-degree murder that included

involuntary manslaughter and stated the following:

[DEFENSE COUNSEL]: . . . . We are also requesting involuntary manslaughter under a different theory. And the theory is that if the jury determines that [Defendant] is not guilty of first-, second- and voluntary, if submitted, on the theory that he did not proximately cause her death, then we would submit that an involuntary manslaughter is appropriate under the theory that, based on the video, he -- and text messages and circumstantial evidence, that he would’ve had knowledge of her drug use and did not adequately get her any medical assistance, and as a result of no medical assistance, [Mrs. Brichikov] expired.

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State v. Brichikov, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-brichikov-ncctapp-2022.