In addressing the harmless error issue, the Court first observed that the State must prove every essential element of a crime beyond a reasonable doubt for a conviction to be upheld. See: In re Winship, 397 U.S. 358, 364, 90 S. Ct. 1068, 1072, 25 L. Ed. 2d 368 (1970); State v. Acosta, 101 Wn.2d 612, 615, 683 P.2d 1069 (1984); State v. McCullum, 98 Wn.2d 484, 493-94, 656 P.2d 1064 (1983); State v. Green, 94 Wn.2d 216, 224, 616 P.2d 628 (1980). The Court also noted that a conviction cannot stand if the jury was instructed in a manner that would relieve the State of this burden. State v. Jackson, 137 Wn.2d 712, 727, 976 P.2d 1229 (1999) (noting that "'the State must prove every essential element of a crime beyond a reasonable doubt for a conviction to be upheld. It is reversible error to instruct the jury in a manner that would relieve the State of this burden.'" (quoting State v. Byrd, 125 Wn.2d 707, 713-14, 887 P.2d 396 (1995))).