Under the traditional common law, the guilt or innocence of a person relied upon whether he had committed the crime ("actus reus"), and whether he intended to commit the crime ("mens rea"). However, many modern penal codes have created levels of "mens rea" called modes of culpability, which depend on the surrounding elements of the crime: the conduct, the circumstances, and the result, or what the Model Penal Code calls CAR (conduct, attendant circumstances, result). The definition of a crime is thus constructed using only these elements rather than the colorful language of "mens rea":