What is the current standard of proof in a civil case?

^4. While the court in People v. Bradford (2014) 227 Cal.App.4th 1322 did not reach the issue concerning the appropriate standard of proof, one justice, in his concurring opinion, discussed the three standards of proof (preponderance, clear and convincing, and beyond a reasonable doubt) and expressed his view that "a heightened burden of proof by clear and convincing evidence" (id. at p. 1346, conc. opn. of Raye, J.) appeared to be appropriate in light of the important rights at stake. (Id. at pp. 1350-1351.)