In Fuller v. State, 363 S.W.3d 583 (Tex. Crim. App. 2012), the Court stated that the jury's ability to apply the correct standard of proof remains an issue in every criminal case. Id. at 587. The Court then held that inquiry into whether a prospective juror understands that proof beyond a reasonable doubt must at least constitute a more onerous standard of proof than preponderance of the evidence and clear and convincing evidence is permissible. Id. ("Inquiry into a prospective juror's understanding of what proof beyond a reasonable doubt means constitutes a proper question regardless of whether the law specifically defines that term.") The Court further stated that it is appropriate to explain the contrast among the various standards of proof. Id. at 588. In Fuller v. State, the trial court prohibited defense counsel from asking the members of the jury panel if they understand that proof beyond a reasonable doubt is the highest burden, explaining that "clear and convincing evidence is the type of burden that might be used when someone is committed to an involuntary health institution or when someone is trying to terminate someone's parental rights," and explaining that beyond a reasonable doubt is "higher than the preponderance of the evidence, which is just over 50 percent and that's the kind of burden that might be used in a civil lawsuit when someone is suing over money." Id. at 584. During voir dire in Fuller, defense counsel made no attempt to question the jury regarding the reasonable-doubt burden and lesser burdens. Id. Finding error by the trial court, the Court of Criminal Appeals held: "Inquiry into a prospective juror's understanding of what proof beyond a reasonable doubt means constitutes a proper question regardless of whether the law specifically defines that term. The jury's ability to apply the correct standard of proof remains an issue in every criminal case. If anything, the fact that current case law has come full circle and once again provides jurors with no definition of reasonable doubt only heightens the incentive for the parties to test the understanding of the veniremembers. And it strikes us as particularly apt to inquire whether a prospective juror understands that proof beyond a reasonable doubt must at least constitute a more onerous standard of proof than preponderance of the evidence and clear and convincing evidence. It is but the flip side of the inquiry that prosecutors engage in routinely during voir dire, designed to test whether prospective jurors will hold the State to the inappropriately onerous standard of proof beyond all doubt. While neither area of inquiry purports to assign a precise meaning to the term "reasonable doubt"-leaving that for the jurors themselves to supply, according to their own common-sense understanding of the words-they do serve to set the lawful parameters of reasonable doubt and thereby foster the selection of jurors who will not impose a standard of proof upon the State that they know for sure to be either too lenient (preponderance or even clear and convincing) or too burdensome (all doubt)." Id. at 587.