In Stark v. Superior Court (2011) 52 Cal.4th 368, the California Supreme Court held that section 424, subdivision (a)(1) "requires a broader mental state beyond a mere intent to do the act." (Stark, at p. 395.) "Without a mental state as to legal authorization, a defendant could be convicted of violating the section 424 provisions by simply acting or failing to act, even if he was unaware of the facts, as defined by statute, that made his intent wrongful." (Stark, at p. 396.) "The People must prove, as a matter of fact, both that legal authority was present or absent, and that the defendant knew of its presence or absence." (Stark, at p. 398.) The People must prove "either actual knowledge or criminal negligence in failing to know the legal requirements underlying the section 424 charges." (Stark, at p. 399.)