have implied, though not stated directly, that the Remmer presumption is clearly established federal law under AEDPA, meaning state courts must apply the Remmer presumption to avoid running afoul of the federal Constitution. See Moore v. Knight, 368 F.3d 936, 942-43 (7th Cir.2004) (stating in a post-AEDPA habeas case reviewing a state court conviction, “The post-conviction court’s finding that there was no prejudice was especially unreasonable due to the fact that a presumption of prejudice applies in situations where ex parte communications were made to the jury by a third party”); see also Wisehart, 408 F.3d at 326-28 (noting in a post-AEDPA habeas case that the State must carry the burden of showing harmlessness in a Remmer hearing); Whitehead v. Cowan, 263 F.3d 708 (7th Cir.2001) (<HOLDING>). In Wisehart v. Davis, for instance, we
holding in a postaedpa habeas case that the remmer presumption did not apply due to the innocuous nature of an intrusion upon a jury implying that the remmer presumption could apply in the habeas context holding that the remmer presumption did not apply where the communication was innocuous and the defendant had failed to present evidence that the communication was prejudicial recognizing presumption recognizing a remmer presumption but noting that sometimes the circumstances are such that the remmer presumption does not even apply holding in  2254d context that the state court did not unreasonably apply remmer in concluding wolfe failed to show that a jurors numerous telephone conversations during the course of jury deliberations constituted an impermissible external jury influence