In People v. Garcia (2001) 25 Cal.4th 744, the Supreme Court held that in order to violate Penal Code section 290, a defendant must actually know of the duty to register. ( Id. at p. 752.) Notice alone does not satisfy the statute's requirement of willfulness, although a jury may infer knowledge from proof of notice. (Ibid.) While CALJIC No. 1.20 requires a showing of purpose or willingness to act or fail to act, the instruction is incomplete because it does not include the requirement of actual knowledge. ( Id. at p. 754.) Failure to instruct the jury on the actual knowledge requirement, however, is subject to harmless error analysis under Chapman v. California (1967) 386 U.S. 18, 24, i.e., the error is harmless if it appears beyond a reasonable doubt that it did not contribute to the jury's verdict. ( People v. Garcia, supra, 25 Cal.4th at p. 755.) In People v. Garcia (2001) the California Supreme Court ruled that establishing a willful violation of section 290 requires proof that the defendant actually knew of his duty to register. ( Id. at p. 752.) While a jury might infer knowledge from notice, notice alone does not necessarily satisfy the willfulness requirement. (Ibid.) The jury in Garcia was incorrectly instructed with CALJIC No. 1.20, which states that "willfully" means a purpose or willingness to omit to act and does not require an intent to violate the law. The jury was also incorrectly instructed with CALJIC No. 4.36 that if the defendant voluntarily did that which the law declares to be a crime, it is no defense that he did not know the act was unlawful. However, our Supreme Court held the error was harmless because the court also instructed the jury that it had to find that the defendant (1) was informed of his duty to register and (2) had both read and signed the notification form. Because the defendant testified that he never read the form, the jury's implied finding that the defendant had read the form "necessarily showed that it discredited the only evidence supporting defendant's claim that he did not actually know about his duty to register." In contrast, the prosecution presented strong evidence that the defendant knew of the registration requirements. Based on that record, the court held the error was harmless beyond a reasonable doubt. ( People v. Garcia, supra, 25 Cal.4th at pp. 754-755.) The Supreme Court held that a violation of section 290 requires a showing that the defendant actually knew of the registration requirement. The court reasoned that where a statute involves a willful failure to act, there must be "a 'purpose or willingness' to make the omission. (Pen. Code, 7.) Logically one cannot purposefully fail to perform an act without knowing what act is required to be performed. . . . Accordingly, a violation of section 290 requires actual knowledge of the duty to register. A jury may infer knowledge from notice, but notice alone does not necessarily satisfy the willfulness requirement." ( People v. Garcia, supra, 25 Cal.4th at p. 752.) The court found the instructions in Garcia erroneous for the following reasons: "The court's instruction on 'willfulness' should have required proof that, in addition to being formally notified by the appropriate officers as required by section 290, in order to willfully violate section 290 the defendant must actually know of his duty to register. We also conclude that the court erred in giving an 'ignorance of the law is no excuse' instruction (CALJIC No. 4.36), which on its face would allow the jury to convict defendant of failing to register even if he were unaware of his obligation to do so." ( People v. Garcia, supra, 25 Cal.4th at p. 754.) The erroneous instructions, however, were found harmless beyond a reasonable doubt despite the defendant's claim that he did not remember being told about the registration requirement and the impression given during final arguments that the jury did not have to find actual knowledge to find the defendant guilty. The court reasoned: "At trial, the prosecution presented strong evidence that defendant knew of the registration requirements. The only evidence suggesting that defendant did not actually know of the requirement was defendant's testimony that nobody ever explained his duty to register to him and that he signed but did not read the notice that explained that duty. However, the trial court's instructions required the jury to find that defendant 'was informed of his duty to register under Penal Code Section 290 by an official in charge of the place of confinement,' and that he 'read and signed the form required by the Department of Justice stating that the duty of the person to register under Penal Code Section 290 will be explained to him.' The verdict of guilt shows that the jury made these findings. Thus, the jury found, contrary to defendant's testimony, that he actually read the form that stated, 'I have been notified of my duty to register as a convicted sex offender pursuant to Section 290 of the California Penal Code,' and that went on to specify exactly what that duty was. Under these properly given instructions, therefore, the jury's verdict necessarily shows that it discredited the only evidence supporting defendant's claim that he did not actually know about his duty to register. Given these findings, we conclude beyond a reasonable doubt that the same jury, properly instructed on the knowledge requirement, would also have concluded that he was aware of his duty to register." ( People v. Garcia, supra, 25 Cal.4th at p. 755, ) The Supreme Court recently held that a "willful" failure to register under section 290 requires actual knowledge of the registration requirement. "The word 'willfully' implies a 'purpose or willingness' to make the omission. . . . Logically one cannot purposefully fail to perform an act without knowing what act is required to be performed. As stated in People v. Honig (1996) 48 Cal.App.4th 289, 334 . . .,'the term "willfully" . . . imports a requirement that "the person knows what he is doing." Consistent with that requirement, and in appropriate cases, knowledge has been held to be a concomitant of willfulness. ' Accordingly, a violation of section 290 requires actual knowledge of the duty to register." (Id. at p. 752.) In Garcia, the court found error in the trial court's failure to instruct the jury that the defendant had "willfully" violated the registration requirement of section 290 only if he actually knew of his duty to register. (25 Cal.4th at p. 754.) The court further found, however, that the error was harmless beyond a reasonable doubt, since there was strong evidence that the defendant knew of the registration requirements in any event, and the jury was instructed that it had to find he was informed of his duty to register. Thus, a properly instructed jury would have reached the conclusion that he was aware of this duty. ( Id. at p. 755.)