In State v. Ireland, 773 P.2d 1375, 1380-82 (Utah 1989), Justice Stewart took issue with an instruction that equated "beyond a reasonable doubt" with "an abiding conviction of the truth of the charge." Id. He reasoned that since the standard to be applied is "beyond a reasonable doubt," it followed that any definition of the standard must reference the obstacle--reasonable doubt--to be overcome by the evidence, and must convey the principle that the State must surmount the obstacle of reasonable doubt to justify a conviction. Id.