Is a failure to instruct a jury on criminal negligence a harmless beyond a reasonable doubt?

In any event, the trial court's failure to instruct on criminal negligence was harmless beyond a reasonable doubt. (Chapman v. State of California (1967) 386 U.S. 18.) Nunez has shown no prejudice. He contends "[g]eneral criminal intent is a far less stringent mens rea standard than criminal negligence." Nunez cites no authority for this contention and it misstates the law. The jury instruction for the crime requires the prosecution to prove "[t]he defendant willfully inflicted unjustifiable . . . mental suffering on a child." Our Supreme Court has noted that "willfulness and criminal negligence are not necessarily inconsistent." (Valdez, supra, 27 Cal.4th at p. 791.) While the high court has said "[c]riminal negligence is not a 'lesser state

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