See also Hoar v. Aetna Casualty & Surety Co. , 1998 OK 95, ¶ 17, 968 P.2d 1219, 1223 (when clear and convincing evidence is presented Oklahoma permits reformation of a contract, including an insurance contract, to reflect the understanding of the parties in situations where there is fraud, accident or mutual mistake).State ex rel. Oklahoma Bar Association v. Kruger , 2018 OK 53, ¶ 2, 421 P.3d 306, 309. Compare Whillock v. Whillock , 1976 OK 51, 550 P.2d 558, 560 (clear and convincing standard) with Henry v. Schmidt , 2004 OK 34, ¶ 19, 91 P.3d 651 (federal constitutional protections require proof of the offense beyond a reasonable doubt when a penal sanction is imposed).