How have the courts interpreted the reasonable doubt standard at the penalty phase?

Defendant's principal argument is that the jury had no guidance on the meaning of proof beyond a reasonable doubt and the presumption of innocence, which applied to the prior crimes evidence presented by the prosecution. However, defendant conceded that he was convicted of and committed both prior crimes presented to the jury. There was no contrary evidence. Thus, the only issues governed by the reasonable doubt standard at the penalty phase were conclusively resolved, and there was no occasion for the jury to reevaluate them. (See People v. Cruz (2008) 44 Cal.4th 636, 681, 80 Cal.Rptr.3d 126, 187 P.3d 970; People v. Harris (2008) 43 Cal.4th 1269, 1322, 78 Cal.Rptr.3d 295, 185 P.3d 727.)

[51 Cal.4th 38]