In Ross v. Superior Court (1977) 19 Cal.3d 899, the trial court did not state it was applying the beyond the reasonable doubt standard of proof in finding the defendants guilty of contempt for violating a court order. (Ross, supra, 19 Cal.3d at pp. 902-905.) On appeal, the defendants argued in the absence of an affirmative showing the trial court had employed the correct standard of proof, error must be presumed. (Id. at p. 913.) The California Supreme Court determined nothing in the record indicated the trial court was unaware of, or had decided to depart from, its obligation to apply the reasonable doubt standard. (Ross, supra, 19 Cal.3d at p. 915.) Furthermore, the trial court had characterized the contempt proceedings as quasi-criminal to the parties at one point. (Ibid.)