What is the burden of proof at which a plaintiff must prove they have committed a crime by a preponderance of the evidence?

^2. As noted, our prior holding in Osuna sets the burden of proof at a preponderance of the evidence. We are aware of the recent opinion in People v. Arevalo (2016) 244 Cal.App.4th 836, 852, concluding the burden must be "beyond a reasonable doubt." However, like the court in People v. Berry (2015) 235 Cal.App.4th 1417, 1428, we are not convinced by the arguments for a higher burden at this time. The concerns underlying the rationale for a higher burden can be cured through proper application of settled principles of review.