In Chapman v. California, 386 U.S. 18, 21, 17 L. Ed. 2d 705, 87 S. Ct. 824 (1967) the Supreme Court held that the courts of states are required to apply the "beyond-a-reasonable-doubt" standard to federal constitutional errors because: Whether a conviction for crime should stand when a State has failed to accord federal constitutionally guaranteed rights is every bit as much of a federal question as what particular federal constitutional provisions themselves mean, what they guarantee, and whether they have been denied. With faithfulness to the constitutional union of the States, we cannot leave to the States the formulation of the authoritative laws, rules, and remedies designed to protect people from infractions by the States of federally guaranteed rights. We have no hesitation in saying that the right of these petitioners not to be punished for exercising their Fifth and Fourteenth Amendment right to be silent--expressly created by the Federal Constitution itself--is a federal right which, in the absence of appropriate congressional action, it is our responsibility to protect by fashioning the necessary rule.