Read the following excerpt from a US court opinion:
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645 S.W.2d at 836. Because some could argue that evidence that makes the existence of a fact “highly probable” is not necessarily the same as evidence that produces a firm conviction in the existence of the fact, we reject the “highly probable” formulation. Cf In re L.R.M., 763 S.W.2d 64, 66 (Tex. App.-Fort Worth, 1989, no writ)(stating that “highly probable” inquiry needlessly complicates the standard of review). VII We emphasize that, as appellate courts apply the standard we announce today, they must maintain the respective constitutional roles of juries and appellate courts. An appellate court’s review must not be so rigorous that the only factfind-ings that could withstand review are those established beyond a reasonable doubt. See Santosky, 455 U.S. at 767-69, 102 S.Ct. 1388 . While parental rights are of constitutional
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What is the most suitable continuation to the opinion? Your options are:
A. holding that beyond reasonable doubt standard not required in termination cases
B. holding that presumption of innocence and reasonable doubt standard are constitutionally required in criminal cases
C. holding that harmless beyond a reasonable doubt analysis not applicable in habeas cases
D. holding that failure of trial court to instruct jury that state must prove beyond reasonable doubt killing was not committed in heat of passion required reversal of murder conviction even though there was general charge that state was required to prove each element of offenses beyond reasonable doubt
E. holding that proof of a criminal charge beyond a reasonable doubt is required by the constitution
Reply with [A, B, C, D, E] only.