Is there any error in the test for establishing probable cause?

Appellant concedes that the subject of proximate cause was introduced with the proviso that it had to be established by proof beyond a reasonable doubt. In addition to a specific reasonable doubt instruction on the issue of proximate cause, the district court gave at least four other reasonable doubt instructions, and both parties focused upon a finding of beyond a reasonable doubt in their closing arguments. Even if we assume that the instruction was error, the court must ask whether it was cured "in the context of the instructions as a whole and the trial record." Estelle v. McGuire, 502 U.S. 62, 72 (1991). Weighing the use of the word "probable" in the challenged instruction against the otherwise pervasive issue of "beyond a reasonable doubt" in the jury instructions, there is no reasonable likelihood that the jury would have misunderstood the standard of proof and any error was harmless.