OPINION
RABINOWITZ, Justice.
I. INTRODUCTION
In this petition we are called upon to decide whether due process under Alaska’s Constitution requires that a criminal offense be predicated on proof of more than just simple civil negligence.
II. FACTS AND PROCEEDINGS
Respondent’s conviction stems from the Exxon Valdez incident. On March 24, 1989, Captain Joseph Hazelwood ran his ship aground off Bligh Reef and reported he was “evidently leaking some oil.” Eventually, eleven million gallons poured into Prince William Sound. A jury subsequently convicted Hazelwood of negligent discharge of oil.
The Court of Appeals reversed Hazel-wood’s conviction on the basis that some of the evidence admitted at trial had been derived from Hazelwood’s immunized oil spill report. The court held that these statements could not have been admitted even if they would inevitably have been discovered from an independent source. Hazelwood v. State, 836 P.2d 943 (Alaska App.1992). This Court reversed, holding that the inevitable discovery doctrine does apply to the immunity created by 33 U.S.C. § 1321(b)(5) for oil spill reports. State v. Hazelwood, 866 P.2d 827, 834 (Alaska 1993).
On remand, the Court of Appeals again reversed Hazelwood’s conviction. This time it held that Hazelwood should have been tried under a criminal negligence theory rather than the civil negligence standard of culpability. The court ruled that criminal convictions may be predicated on findings of simple or ordinary negligence only when the offense involves a heavily regulated commercial activity. Hazelwood v. State, 912 P.2d 1266, 1279 (Alaska App.1996). Since the application of former AS 46.03.790 is not restricted to heavily regulated industries, the Court of Appeals concluded that Hazelwood’s conviction under a civil negligence standard was a denial of due process. We granted the state’s petition for hearing and now reverse.
III.DISCUSSION
The difference between criminal and civil negligence although not major is distinct. Under both standards, a person acts “negligently” when he fails to perceive a substantial and unjustifiable risk that a particular result will occur.
The two tests part ways in their descriptions of the relevant unobserved risk. Under ordinary negligence, “the risk must be of such a nature and degree that the failure to perceive it constitutes a deviation from the standard of care that a reasonable person would observe in the situation.” Id. at 1278. Criminal negligence requires a greater risk. This standard is met only when the risk is
of such a nature and degree that the failure to perceive it constitutes a gross deviation from the standard of care that a reasonable person would observe in the situation. Criminal negligence is something more than the slight degree of negligence necessary to support a civil action for damages and is negligence of a degree [878]*878so gross as to be deserving of ‘punishment.
Id. at 1278-79 n. 16 (emphasis added).
In essence, then, the criminal negligence standard requires the jury to find negligence so gross as to merit not just damages but also punishment. It does not spill over into recklessness; there is still no requirement that the defendant actually be aware of the risk of harm. However, criminal negligence does require a more culpable mental state than simple, ordinary negligence.1
The statute under which Hazelwood was convicted provides in relevant part:
A person may not discharge, cause to be discharged, or permit the discharge of petroleum ... into, or upon the waters or land of the state except in quantities, and at times and locations or under circumstances and conditions as the department may by regulation permit....
Former AS 46.03.790(a) (current AS 46.03.740). At the time of the alleged crime, a person who “negligently” violated this provision was guilty of a class B misdemeanor. Id.2
The Court of Appeals concluded that the unadorned use of the word “negligently” created an ambiguity as to whether the statute rests on criminal or ordinary negligence. Relying on its past decisions, the court held that criminal liability may be imposed on the basis of simple or ordinary negligence “only for offenses dealing with heavily regulated activities for which permits or licenses are required.” Hazelwood, 912 P.2d at 1279 (quoting Cole v. State, 828 P.2d 175, 178 (Alaska App.1992)).3
In defense of the Court of Appeals’ ruling, Hazelwood presents two lines of argument. First, he contends the guarantee of due process demands that criminal penalties be predicated on more than just ordinary negligence. He reads our precedents as requiring a mens rea of at least reckless culpability for criminal offenses. Second, Hazelwood maintains that the statute under which he was convicted itself incorporates the criminal negligence standard. We address each argument in turn.
A. Due Process and a Civil Negligence Mens Rea Standard
1. Alaska law
Hazelwood grounds his due process claim in our decisions in Hentzner v. State, 613 P.2d 821 (Alaska 1980); Kimoktoak v. State, 584 P.2d 25 (Alaska 1978); Alex v. State, 484 P.2d 677 (Alaska 1971); and Speidel v. State, 460 P.2d 77 (Alaska 1969). He contends that in each of these cases we required a showing of recklessness, or subjective awareness of wrongdoing, in order to sustain the criminal conviction.
These decisions stand for a common proposition: that criminal convictions must be predicated on criminal intent.4 In other words, there must be some level of [879]*879mental culpability on the part of the defendant. However, this principle does not preclude a civil negligence standard. What it does mean is that we will generally read into a criminal statute some level of mens rea, “as opposed to strict criminal liability.” Alex, 484 P.2d at 681 (emphasis added); see also Kimoktoak, 584 P.2d at 29. It is strict liability, and not the negligence standard, which “is an exception to the rule which requires criminal intent.” State v. Rice, 626 P.2d 104, 108 (Alaska 1981). The requirement of criminal intent does “not emphasize a specific awareness of wrongfulness.” Alex, 484 P.2d at 681.5
The point is illustrated by State v. Guest, 583 P.2d 836 (Alaska 1978), and Rice, 626 P.2d at 104. In each case, we upheld the imposition of criminal sanctions on the basis of simple, ordinary negligence. Guest approved the Superior Court’s instruction that the defendant was not guilty of statutory rape if he reasonably believed his victim was of consenting age. In effect, we sustained prosecution on charges that the defendant was negligent as to the victim’s age. See Guest, 583 P.2d at 839 n. 5 (quoting Wayne R. LaFave & Austin W. Scott, Jr., Criminal Law § 47, at 356-57 (1972)). Similarly, Rice read into a criminal prohibition on transportation of illegally taken game a requirement that the defendant was at least negligent as to the fact the game was illegally taken. See Rice, 626 P.2d at 110. In both cases, a mens rea of simple or ordinary negligence was made the basis of the offense.
2. Hazelwood’s conduct!circumstances distinction
Hazelwood distinguishes Rice and Guest on the ground that in each the negligence standard was applied only to the circumstances of the crime, not the underlying conduct. Due process, he maintains, still requires the government to demonstrate there was “volitional conduct of the prohibited act.”
Hazelwood’s conduct/circumstances distinction is untenable. As an initial matter, we note that nowhere do our due process precedents differentiate between the minimum mens rea for circumstances and conduct. Nor is there any reason to do so. In many cases, it is only the circumstances of the offense that render it objectionable. No one would suggest, for example, that Rice’s transportation of game would still have been criminally sanetionable had it not been taken illegally. The statute proscribes the underlying conduct only when the relevant circumstance is present. The same was true in Guest. Indeed, in both cases, had we not applied a negligence standard to the circumstance of the offense, it would have included no mens rea element whatsoever.
We think Hazelwood confuses volition with intent. While many crimes do not require that their .underlying action be carried out with a guilty mind, it is always a defense to prosecution that the conduct was not voluntary. In every case, the alleged infraction must have been the product of a free will, and not coercion, duress, or mental illness. Had terrorists boarded the Exxon Valdez, for example, and demanded that Ha-zelwood run his vessel onto Bligh Reef, the fact that he did so even with knowledge and purpose would be irrelevant. He could defend on the basis that his act was not voluntary, and thus could not be properly attributed to him. This is not the case here. Hazelwood faced no compulsion that would excuse his conduct at the time the Exxon Valdez rammed into Bligh Reef. While there is a voluntariness element to every criminal offense, because Hazelwood’s commissions were his and his alone, .this prerequisite is satisfied here.6
As noted above, it is firmly established in our jurisprudence that a mental state of simple or ordinary negligence can support a criminal conviction. Further decisions reveal, however, that in some situations more will be required, and sometimes less. Spei[880]*880del, 460 P.2d at 80, found a denial of due process where the defendant had been convicted of “simple neglectful or negligent failure to return a rented automobile.” In that case, we insisted on at least a finding of reckless culpability in order for criminal sanctions to be imposed.
On the other hand, elsewhere we have allowed the mens rea element to be dispensed with entirely. We have allowed strict liability to be read into “public welfare offenses.” See, e.g., Rice, 626 P.2d at 107. These public welfare offenses are proscriptions which “heighten the duties of those in control of particular industries, trades, properties or activities that affect public health, safety or welfare.” Morissette v. United States, 342 U.S. 246, 254, 72 S.Ct. 240, 245, 96 L.Ed. 288 (1952). See also Haxforth v. Idaho, 117 Idaho 189, 786 P.2d 580, 582 (App.1990) (four-part test). As a corollary, a mens rea requirement is imputed only when a serious penalty attaches. See Guest, 583 P.2d at 838; Kimoktoak, 584 P.2d at 29; and Speidel, 460 P.2d at 80; see also People v. Olson, 181 Mich.App. 348, 448 N.W.2d 845, 847 (1989). Also, no mental element will be required when a statute provides “clear legislative intent to the contrary.” Rice, 626 P.2d at 108; see also Lambert v. California, 355 U.S. 225, 228, 78 S.Ct. 240, 242-43, 2 L.Ed.2d 228 (1957) (“There is wide latitude in the lawmakers to declare an offense and to exclude elements of knowledge and diligence from its definition.”); cf. Gregory v. State, 717 P.2d 428, 430 (Alaska App.1986).
An explanation of why the simple or ordinary negligence standard is nevertheless appropriate in this case requires consideration of the reasons that variable levels of mens rea will satisfy due process for different offenses.
3. The strict liability tradition
The rule that a criminal offense exists at the intersection of a guilty act and a guilty mind is commonly viewed as the bedrock of criminal common law. Over two centuries ago, Blackstone wrote, “[T]o constitute a crime against human laws, there must first be a vicious will, and secondly an unlawful act consequent upon such a vicious will.” 4 Comm. 21. A century and a half later Bishop affirmed: “There can be no crime large or small without an evil mind.” 1 Bishop, Criminal Law (9th ed.1930) § 287.7
Yet throughout our common law history, a parallel tradition has allowed imposition of penalties without formal proof of criminal intent. An early version of strict liability, the law of deodands, has been traced back to early Western history. A deodand was an object that was forfeited to the Crown for directly or indirectly causing the death of a human being. See generally, Oliver Wendell Holmes, Jr., The Common Law 24-25 (1881). The original reasoning was that the instrument itself was guilty of the offense.
Although the deodand form was abolished in England in 1846, 9 & 10 Vict. c. 62, and never was incorporated into the American common law, see Parker-Harris Co. v. Tate, 135 Tenn. 509, 188 S.W. 54 (1916), its substance survives in contemporary in rem proceedings. The object itself, rather than its human owner, is formally charged. See, e.g., One 1958 Plymouth Sedan v. Pennsylvania, 380 U.S. 693, 85 S.Ct. 1246, 14 L.Ed.2d 170 (1965); United States v. 43 Gallons of Whiskey, 93 U.S. 188, 23 L.Ed. 846 (1876); United States v.1960 Bags of Coffee, 12 U.S.(8 Cranch) 398, 3 L.Ed. 602 (1814). The Supreme Court of the United States has recently affirmed that proof of the moral culpability of the owner is not a necessary predicate to these punitive forfeitures. See Bennis v. Michigan, — U.S.—, 116 S.Ct. 994, 134 L.Ed.2d 68 (1996). Bennis upheld a modern-day deodand of sorts, allowing the state to seize and forfeit an automobile without any showing that the owner knew her husband might use the vehicle to solicit prostitutes. Id.
In the same year the deodand rule was repealed in England, a new practice began to develop in its place on both sides of the [881]*881Atlantic. In Regina v. Woodrow, 15 M. & M. 404 (Exch.1846),the Court of Exchequer allowed the imposition of a £200 fine on a tobacco dealer for possession of adulterated tobacco, without evidence the dealer “had knowledge or cause to suspect” the product’s condition. Per Pollock, C.B., at 415, 416. The case was reaffirmed in Regina v. Stephens, L.R. 1 Q.B. 702 (1886). The Court accepted that a new class of offenses without a mens rea element had come into being. While many of these statutes were a product of technological change8 or modern sensibilities,9 and thus had no common law antecedent, others overlaid old crimes which had once included an intent element.10 The Court summed up the development in Cundy v. LeCocq, L.R. 13 Q.B.D. 207 (1884):
In old time, and as applicable to the common law or to earlier statutes the maxim [that in every criminal offense there must be a guilty mind] may have been of general application; but a difference has arisen owing to the greater precision of modern statutes. It is impossible now ... to apply the maxim generally to all statutes, and the substance of all the reported cases is that it is necessary to look at the object of each Act that is under consideration to see whether and how far knowledge is of the essence of the offence created.
Id. at 210 (Stephen, J.) (upholding strict liability conviction for selling alcohol to an intoxicated person).
On this shore, courts also began to allow penalties for certain offenses without proof of intent during this era. The practice first took root in Massachusetts, apparently quite independently of the English cases, and spread quickly from there.11 Again, crimes which had recently required criminal intent could now be punished without it.12
4. Theories of strict liability
Over the years, several authorities have attempted to define the appropriate role and scope of the strict liability offense. In 1933, Professor Sayre catalogued all such crimes appearing in reports. His classifications include sales of alcohol to minors, alcoholics, Indians, soldiers, students and slaves; sales of impure foods, particularly milk and butter; sales of misbranded articles; and various automobile and traffic regulations. See Sayre, supra n. 11, at 84-87. However, Professor Sayre was unable to avoid employing the broad categories of “Criminal Nuisances” and “General Police Regulations for the Safety, Health or Well-Being of the Community.” He recommends that strict liability crimes be enforced with light penalties, though he concedes this limit has not been followed. Id. at 72, 79-82. He concludes with the generality that the abandonment of mens rea is suited to situation's where the need for social order outweighs the need for individualized punishment.13 Id.
[882]*882Some jurisdictions differentiate between offenses that are mala in se and mala prohi-bita, allowing strict liability only for the latter. See Sayre, supra n. 11, at 70 n. 55. Although this court has relied on this difference, these other jurisdictions’ decisions are of little guidance to us, as we have drawn the opposite conclusion from the distinction. See Hentzner, 613 P.2d at 826 (separate intent element not necessary for offenses that are mala in se).
Generally, those courts that dispense with criminal intent for crimes that are mala prohibited that is, not patently immoral, have followed the rationale that the legislature did not intend these new offenses to carry a mental element. The very meaning of ma-lum prohibitum is that it is wrong because it is prohibited. Common law crimes, which by their nature are wrongful, require scienter because moral culpability is inherent to the offense. The courts have reasoned, however, that when conduct is penalized only because of a legislative command, then the nature of the proscription derives solely from that mandate. If the statute did not include a mental element, then the crime was not meant to have one.
The malum in se /malum prohibitum distinction overlaps with another theme in this area, that of deference to legislative direction. Courts routinely hold that whether scienter is an element of a charged offense “is a question of legislative intent to be construed by the Court.” United States v. Balint, 258 U.S. 250, 252, 42 S.Ct. 301, 302, 66 L.Ed. 604 (1922). Even Morissette concedes that the concerns raised by the exclusion of mens rea “would not justify judicial disregard of a clear command to that effect from Congress.” Morissette, 342 U.S. at 254 n. 14, 72 S.Ct. at 245 n. 14. Compare State v. Rice, 626 P.2d 104, 108 (Alaska 1981). Since, by its terms, the malum prohibitum offense is a creature of statute rather than common law, it is here that courts will most often defer to legislative intent.
Although widely accepted, the mala in se and legislative discretion approaches in our view remain unsatisfactory. We note that even crimes which had traditionally required proof of criminal intent have been recharacterized as strict liability crimes. See, e.g., McCutcheon, 69 Ill. at 601; Baltimore & Susqu. Steam Co., 13 Md. at 186. Nevertheless, we reject any rule that grants the legislature unbridled discretion to impose strict liability crimes. An exception to the mens rea requirement for “clear legislative intent to the contrary” has the potential to swallow the rule. As we said in Speidel, even where a statute is explicit, due process will on occasion require a higher degree of culpability. 460 P.2d at 80 (replacing the negligence threshold of AS 28.35.026 with a recklessness standard).
5. The principle of reasonable deterrence
An appropriate place to begin an explanation for objective fault crimes14 is with the objections of those who would abolish them altogether. In Jerome Hall, Negligent Behavior Should Be Excluded from Penal Liability, 63 Colo. L.Rev. 632 (1963), Professor Hall challenges the alleged utility of sanctions based on negligence and strict liability. He contends crimes that are not based on subjective awareness of wrongdoing are, by their terms, not addressed to “the extremely important degree of individual freedom, autonomy, and awareness ... expressed in (voluntary) action by a normal adult.” Id. at 637. Merely negligent harm doers, contends Professor Hall, “have not in the least thought of their duty, their dangerous behavior, or any sanction.” Id. at 641 (footnote omitted).
The difficulty with this thesis is that it assumes legal regulations can operate only through the offender’s conscious reason. A rebuttal is supplied by Professor Hart:
the connexion between the threat of punishment and subsequent good behavior is not [always] of the rationalistic kind pic[883]*883tured in the guiding-type of case. The threat of punishment is something which causes [the offender] to exert his faculties, rather than something which enters as a reason for conforming to the law when he is deliberating whether to break it or not. It is perhaps more like a goad than a guide. But there seems to me to be nothing disreputable in allowing the law to function in this way, and it is arguable that it functions in this way rather than in the rationalistic way more frequently than is generally allowed.
H.L.A. Hart, Punishment and Responsibility 134 (1968).
The law’s “goad,” rather than its guide, is also emphasized by Professor LaFave. He asks whether more than civil negligence should be required for a criminal offense, and concludes “that there is no need to choose one answer for all crimes.” His primary focus is on deterrence:
The principal policy question is whether the threat of punishment for objective fault will deter people from conducting themselves in such a way as to create risk to others. Though the matter is disputed, it would seem that some people can be made to think, before they act, about the possible consequences of acting, so that the existence of objective-fault crimes does tend to reduce risky conduct.... The point is that the legislature might, in the exercise of its police power, require subjective fault for some crimes and objective fault for other crimes.
1 LaFave at 337-38 (footnotes omitted).
It is here, grounded in a theory of reasonable deterrence, that any explanation for objective fault crimes must have its origins. Despite Professor Hall’s challenge, it cannot be disputed that the threat of punishment necessarily deters. Even when an offender does not of his own accord realize that his conduct is wrongful, he can in many cases be made to take care. Coercion that causes the offender to pay attention can serve important social aims that would not be achieved by proscriptions that only come into effect when the transgressor recognizes the harm in his or her behavior.
The fulcrum for deciding what level of intent is the absolute minimum for a particular offense is a question of when an expectation of individual conformity is reasonable. Due process under Alaska’s Constitution requires that social interests be weighed against those of the individual. While society’s interest in obtaining compliance with its regulations is strong, it can never outweigh the individual’s interest in freedom from substantial punishment for a violation he or she could not reasonably have been expected to avoid. The threshold question, then, is whether the defendant’s conduct is something which society could reasonably expect to deter.
The principle of reasonable deterrence allows the imposition of strict liability in some circumstances. Generally, a separate mental element need not be proved when the failure to abide by a rule is inherently unreasonable. This occurs, for instance, where a person’s conduct is hedged in by regulation, such that one may readily assume his or her routine decisions are guided by rules. Thus, strict liability is permitted for heavily regulated industries. See Cole v. State, 828 P.2d 175, 178 (Alaska App.1992). Persons operating in rule-laden environments, and whose actions have a substantial impact on public health, safety, or welfare, can reasonably be assumed aware of their governing codes.
Another type of law whose violation is inherently unreasonable is the malum in se offense. As we explained in Hentzner, these are crimes which “reasoning members of society regard as condemnable,” such that “awareness of the commission of the act necessarily carries with it an awareness of wrongdoing.” 613 P.2d at 826.
Finally, an exception exists for those regulations which call for only a modest fine. Generally, their underlying conduct is not so inherently unwholesome that it can be reasonably assumed the misdemeanant was aware of its wrongfulness. Indeed, these punishments usually aim to coerce the public at large, and are meant to influence behavior by their very infliction. There is no implied assumption that the transgressor reasonably should have been aware he or she had [884]*884stepped outside the law. Broad strict liability of this sort normally would run afoul of due process,15 but here it is allowed because the penalties are light.
Reasonable deterrence, then, is the basic principle of the due process balance between individual and societal interests. The ultimate question is whether society can reasonably expect the individual to conform his or her conduct to the law. For the strict liability exceptions, a separate showing of a departure from social mores is unnecessary, as it can reasonably be presumed.16 This notion of a duty of reasonable social conformity undergirds the entire law of mens rea.
Within the confines of this understanding, we will defer to the legislature’s directives. It appropriately decides what conduct is inherently wrongful to reasoning members of society and when the social interest requires enforcement without mens rea. However, for deference to be accorded, it must be reasonably apparent that the enactment was in exercise of such judgment. Strict liability cannot be applied simply to expedite punishment when there is no reasonable expectation of deterrence.
6. The sufficiency of simple negligence
Outside of these strict liability exceptions, though, a separate showing of simple civil negligence is both necessary and sufficient under Alaska’s Constitution. Negligence, rather than gross negligence, is the minimum, not because we believe it is the necessary element of every prosecutor’s case; indeed, all courts have allowed a separate showing of mental culpability to be dispensed with altogether in some circumstances. Rather, the negligence standard is constitutionally permissible because it approximates what the due process guarantee aims at: an assurance that criminal penalties will be imposed only when the conduct at issue is something society can reasonably expect to deter.17
Partisans of the criminal negligence approach have expressed the concern that an ordinary negligence standard gives the criminal proceeding an unseemly resemblance to tort law. Commonwealth v. Heck, 341 Pa.Super. 183, 491 A.2d 212, 224 (1985), aff'd, 517 Pa. 192, 535 A.2d 575 (1987), which adopts criminal negligence as a minimum, notes that the civil law standard serves purposes unsuited to the “harshness of criminal punishment.” Tort aims simply to “shift the economic costs of injuries onto those responsible for them.”18 Id.
This desire to differentiate criminal proceedings from civil proceedings appears to [885]*885drive the definition of criminal negligence. That standard is typically characterized as “something more” than ordinary negligence. See Andrews v. Director of Pub. Prosecutions, 26 Crim.App. Rep. 34 (1937) (“similar lack of care such as will constitute civil liability is not enough”) (Lord Atkin). Thus the only consensus and precision available in the definition of criminal negligence is that it is not civil negligence.19
This fear of tort standards is unfounded. In response to similar allegations that civil standards do not protect, the Michigan Supreme Court has noted that “[i]t is just as much a violation of the due process clause of the Constitution to take property as it is to take the liberty of a person.” People v. McMurchy, 249 Mich. 147, 228 N.W. 723 (1930). In other words, the same constitutional clause which governs the criminal prosecution would also govern a civil proceeding, and it is undisputed that due process is satisfied by the negligence standard in that forum.
We are not persuaded that the simple or ordinary civil negligence standard is inadequate to protect Hazelwood’s interests. We conclude that the Superior Court’s adoption of an ordinary civil negligence mens rea standard in its instructions to the jury did not constitute a denial of due process under article I, section 7 of the Alaska Constitution.
B. The Statute
Hazelwood next contends that the statute under which he was convicted, former AS 46.03.790(a), itself incorporates the criminal negligence mens rea standard. His argument is unconvincing. The legislature made “negligence” the standard of liability. Unadorned, this word is commonly understood to mean ordinary negligence, not criminal or gross negligence. Nowhere in the criminal code is an ordinary negligence standard applied through the words “civil negligence” or “ordinary negligence.” These added terms are used only when differentiating common negligence from criminal negligence. Otherwise, criminal negligence is always referred to specifically, and “negligence” always denotes ordinary, civil negligence.20
Hazelwood also contends that the legislative history of AS 46.03.790(a) points to an intent to incorporate a criminal negligence standard. Specifically, he relies on Governor Sheffield’s transmittal letter accompanying the proposed bill that eventually added the negligence standard to § 790.21 The letter states that the proposed change aims to
bring the existing provisions into conformity with language and penalty levels in the Revised Criminal Code....
[To this end, it recommends] changing the criminal “state of mind” provision from “willful” to “knowing,” for class A misdemeanors, while making clear that “negligent” violations are intended to be class B misdemeanors....
1984 Alaska Senate Journal 2079-80.
Hazelwood contends that the reference to the Revised Criminal Code suggests an intent to adopt the “criminal negligence” standard defined in the Code. We draw the opposite inference. The Governor’s letter exhibits an awareness of the Code and its provisions, which included the criminal negligence standard. Yet the letter only speaks of negligence, not the special criminal negligence test. We can only conclude that the Governor’s office knew of the criminal negligence provision and consciously chose to forego this more exacting standard in favor of simple negligence. This interpretation is consistent with the settled rule that a difference in language implies a dif[886]*886ference in meaning. See Neal v. Honeywell, Inc., 33 F.3d 860, 863 (7th Cir.1994); United Parcel Serv. v. State, Dep’t of Revenue, 102 Wash.2d 355, 687 P.2d 186, 191 (1984).
IV. CONCLUSION
The Superior Court’s adoption of an ordinary negligence standard was not erroneous. We therefore REVERSE the holding of the Court of Appeals on this issue. The case is remanded to the Court of Appeals for consideration of any unresolved issues originally raised by Hazelwood on appeal.22
EASTAUGH and FAJBE, JJ., not participating.