at 276-77. The conviction was reversed because the prosecution failed to prove criminal negligence, an essential element of the crime. Id. at 511-12, 82 P.2d at 281-82. “Mere negligence is not sufficient. It may be sufficient to compel the driver to respond in damages. However, when it comes to responding to an accusation of involuntary manslaughter, with the possibility of a penitentiary sentence, a different rule is called into play.” Id. at 513, 82 P.2d at 281 (Zinn, J., specially concurring). 13. We have continued to follow the logic of the Harris case each time the Court has been presented with the issue of the degree of negligence required for an involuntary-manslaughter conviction arising from an automobile accident. See State v. Hayes, 77 N.M. 225, 226, 421 P.2d 439, 439 (1966) (<HOLDING>); State v. Clarkson, 58 N.M. 56, 60, 265 P.2d
holding that no consideration existed for part of the settlement holding that the culpable state of mind for involuntary manslaughter comprehends evidence of an utter irresponsibility on the part of the defendant or of a conscious abandonment of any consideration for  safety holding that erroneous manslaughter instruction that defendant intentionally caused the death of the victim did not constitute fundamental error certifying question  if a jury returns a verdict finding a defendant guilty of seconddegree murder in a case where the evidence does not support a theory of culpable negligence does a trial court commit fundamental error by giving a flawed manslaughter by act instruction when it also gives an instruction on manslaughter by culpable negligence recognizing involuntary manslaughter as an offense that does not in and of itself constitute a crime involving moral turpitude for purposes of attorney disbarment holding erroneous jury instruction on manslaughter by intentional act not fundamental error where trial court also instructed jury on manslaughter by culpable negligence