What is the range of reasonable doubt and the level of proof required for a jury to convict the same charges in different circumstances?

Although the relatively unsophisticated survey summarized below reveals that most differences in the wording of charges do not suggest to jurors substantially different levels of proof necessary to convict, it should be recognized that the sample size is too small to permit any conclusive finding. The results do suggest, however, that with the exception of one charge that improperly uses the moral certainty language (see letter M in Table of Results, infra.), the range of probability the average juror, in this survey, would need to convict is relatively close under any proposed definition. The average ranges from 79.4% to 93.9%. Cf. United States v. Fatico, 458 F.Supp. 388, 410 (E.D.N.Y.1978) (judges' estimates of probability required under the reasonable doubt standard range from 76% to 95%).