U.S. v. Lopez, 04-2254 (8th Cir., Apr. 17, 2006) over time,the court's application of the slight evidence standard has become careless, migrating away from the reasonable doubt requirement. Accordingly, the Court decides to join the First, Fourth, Fifth, Seventh, Ninth and Eleventh Circuits in rejecting the slight evidence standard. the government must prove beyond reasonable doubt that a defendant is a member of a conspiracy. Such a principle is of course irreconcilable with the long-accepted burden of proof in criminal cases, see In re Winship, 397 U.S. 358, 361-64 (1970), and it is particularly unwarranted in conspiracy law, where the government has the ability to hold relatively small players responsible for a wide range of criminal conduct. See United States v. Martinez de Ortiz, 883 F.2d 515, 524 (7th Cir. 1989) (Easterbrook, J., concurring), reh'g granted and judgment vacated on other grounds, 897 F.2d 220 (7th Cir. 1990).