In Ex parte Elizondo, 947 S.W.2d 202 (Tex. Crim. App. 1996), the Court held that a bare innocence claim is cognizable in an application for writ of habeas corpus. Elizondo, 947 S.W.2d at 205. Incarceration of an innocent person offends federal due process, therefore a bare innocence claim raises a constitutional challenge to the conviction. Ibid. But we also said that a conviction should not be overturned lightly and that the burden on the applicant who has had error-free proceedings is exceedingly heavy to take into account society's and the State's interest in finality. Elizondo, 947 S.W.2d at 208. To be granted relief on a bare innocence claim, the applicant must show that the new evidence unquestionably establishes his innocence. Id. at 208-09. The Court interpreted this to mean that the applicant must prove by clear and convincing evidence that no reasonable juror would have convicted the applicant in light of the new evidence. Id. at 209. To determine whether a habeas applicant has reached this level of proof, the convicting court weighs the evidence of the applicant's guilt against the new evidence of innocence. Id. at 207. In Elizondo, the Court said that our job was to "decide whether the newly discovered evidence would have convinced the jury of applicant's innocence." Ibid. That was in the context of that case, in which a jury had decided Elizondo's guilt. But we said a bare innocence claim is not an attack on the jury's verdict. Id. at 209. "What the applicant wants is a new trial based on newly discovered evidence which he claims proves his innocence." Ibid. In Elizondo, the Court explained the task in evaluating actual innocence claims: Because, in evaluating a habeas claim that newly discovered or available evidence proves the applicant to be innocent of the crime for which he was convicted, our task is to assess the probable impact of the newly available evidence upon the persuasiveness of the State's case as a whole, we must necessarily weigh such exculpatory evidence against the evidence of guilt adduced at trial. See Elizondo, 947 S.W.2d at 206. Applicant presented the Court with a Herrera-type claim. Applicant raised a claim of actual innocence based upon the recantation of testimony given by one of the victims of a crime for which applicant was convicted. The Court determined that the standard set by this Court in Holmes, which was decided prior to Schlup, made it "theoretically impossible" for any habeas applicant to gain relief. Elizondo, 947 S.W.2d at 205. In Holmes we held that "in order to be entitled to relief on a claim of factual innocence the applicant must show that based on the newly discovered evidence and the entire record before the jury that convicted him, no rational trier of fact could find proof of guilt beyond a reasonable doubt." 885 S.W.2d at 398. As such, we turned to Schlup for guidance and modified the standard to be applied in Herrera-type claims. The Court determined the "unquestionably establish" language as meaning the same thing as "clear and convincing." Elizondo, 947 S.W.2d at 209. In Elizondo the Court explained: Because, in evaluating a habeas claim that newly discovered evidence or available evidence proves the applicant to be innocent of the crime for which he was convicted, our task is to assess the probable impact of the newly available evidence upon the persuasiveness of the State's case as a whole, we must necessarily weigh such exculpatory evidence against the evidence of guilt adduced at trial. 947 S.W.2d at 206.