What is the current state of the law on the doctrine of proof by more than a preponderance in non-fraud cases?

"The same reasoning--i.e., that judicial expressions purporting to require clear and convincing evidence must be read in light of the statutory provision for proof by a preponderance of the evidence--has been invoked in nonfraud cases as well. [Citations.]" (Liodas v. Sahadi, supra, 19 Cal.3d 278, 289, fn. 6, 137 Cal.Rptr. 635, 562 P.2d 316.) ³ "The foregoing decisions of this court should have laid to rest the early belief that civil fraud must be proved by more than a preponderance of the evidence. Any lingering doubt on the point, moreover, should have been removed by the enactment of the Evidence Code." (Id., at p. 289, 137 Cal.Rptr. 635, 562 P.2d 316.)