What is the burden of proving harmless contact with a juror?

Further, the evaluation of claims of juror misconduct depends on whether the misconduct is based on extrinsic influences or intrinsic influences. When the misconduct stems from an extrinsic or external influence, prejudice is presumed unless the government shows it was harmless. See United States v. Remmer, 347 U.S. at 228-29 (1954); Xiong v. Felker, 681 F.3d at 1076 (9th Cir. 2012) ("The presumption of prejudice that arises from juror misconduct, although strong, is not conclusive; 'the burden rests heavily upon the Government to establish, after notice to and hearing of the defendant, that such contact with the juror was harmless to the defendant.'") The situation is different when the alleged misconduct is intrinsic to the jury's deliberations.