What is the current state of the law on the doctrine of "proceeding beyond a reasonable doubt"?

I have recently come to question this court's doctrine.² It has not always been

[228 F.2d 809]

accepted by our court. See United States v. Wishnatzki, 2 Cir., 77 F.2d 357, 360; cf. Fraina v. United States, 2 Cir., 255 F. 28, 35. Some federal courts of appeal and some state courts do not now accept it. Some state appeal courts flatly state that they will reverse if the evidence does not show guilt beyond a reasonable doubt.³ Some federal appellate courts say that a conviction must be reversed unless the evidence is "inconsistent with every reasonable hypothesis of * * * innocence", or "unless there is substantial evidence of facts which exclude every hypothesis but that of guilt," or the like.⁴

[228 F.2d 809]