Does the failure to instruct juries in criminal trials that the prosecution must prove each element of the charged crime beyond a reasonable doubt violate Winship?

QUESTION PRESENTED Per In re Winship, 397 U.S. 358 (1970), the state must prove each element of the offense beyond a reasonable doubt “and a jury instruction violates due process if it fails to give effect to that requirement.” Middleton v. McNeil, 541 U.S. 433, 437 (2004). California has cut this “each element” requirement from its criminal jury instructions. They now only say that the prosecution must prove a defendant “guilty” beyond a reasonable doubt. California, which holds more felony jury trials than any U.S. jurisdiction, is the lone jurisdiction that does not include “each element” or equivalent language in its instructions. The California Supreme Court holds that this is not error, squarely conflicting with the high courts of New York and Pennsylvania on the question presented: Does the failure to instruct juries in criminal trials that the prosecution must prove each element of the charged crime beyond a reasonable doubt violate Winship? i