It is difficult, if not impossible, to so define the term “reasonable doubt” as to satisfy a subtle and metaphysical mind, bent on the detection of some point, however attenuated, upon which to hang a criticism. —Supreme Court of VirginiaMcCue v. Commonwealth, 103 Va. 870 at 1002 (1905).

I find it rather unsettling that we are using a formulation that we believe will become less clear the more we explain it. —Jon Newman, Chief Judge of the U.S. Court of Appeals for the 2nd CircuitJon. O. Newman, Beyond “Reasonable Doubt,” N.Y.U. L. REV. 979, 984 (1993).

The complete lack of controversy that surrounds the reasonable doubt standard implies that we are pretty happy with the way the standard operates. —Erik LillquistErik Lillquist, Recasting Reasonable Doubt: Decision Theory and the Virtues of Variability, U.C. DAVIS L. REV. 85, 190–191 (2002).