 How to define standards of proof, or whether they should be even defined in the first place, remains contentious (Diamond 1990; Horowitz and Kirkpatrick 1996; Laudan 2006; Newman 1993; Walen 2015). Judicial opinions offer different paraphrases, sometimes conflicting, of what these standards mean. The meaning of “proof beyond a reasonable doubt” is the most controversial. It has been equated to “moral certainty” or “abiding conviction” (Commonwealth v. Webster, 59 Mass. 295, 1850), or to 