The following excerpt is from Valdez v. Wong, 1:09-cv-01555-JLT HC (E.D. Cal. 2011):
In reaching its decision, the 5th DCA expressly cited Winship as requiring proof beyond a reasonable doubt in order to satisfy due process concerns, and cited Victor v. Nebraska, 511 U.S. 1, 5 (1994), for the propositions that there is no standard formula for instructing on the meaning of reasonable doubt and that as "long as the court instructs the jury on the necessity that the defendant's guilt be proved beyond a reasonable doubt, the Constitution does not require that any particular form of words be used in advising the jury of the government's burden of proof." (LD 4, p. 9).
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