opportunity “to reconcile existing New Mexico precedent with this more recent articulation by the Supreme Court.” Mann, 2002-NMSC-001, ¶ 36, 131 N.M. 459, 39 P.3d 124. {19} A review of our case law reveals that, like the United States Supreme Court, the courts of this state have refined and narrowed the presumption of prejudice over time. First, the presumption of prejudice is not automatic in nature; rather, the party moving for a new trial bears the burden to “‘make a preliminary showing that movant has competent evidence that material extraneous to the trial actually reached the jury.’ ” State v. Sena, 105 N.M. 686, 688, 736 P.2d 491, 493 (1987) (quoting State v. Doe, 101 N.M. 363, 366, 683 P.2d 45, 48 (Ct.App.1984)); see also Mann, 2002-NMSC-001, ¶ 19, 131 N.M. 459, 39 P.3d 124 (<HOLDING>). Notably, not all extraneous material is
holding that the party seeking a new trial must make an affirmative showing that some extraneous influence came to bear on the jurys deliberations internal quotation marks and citation omitted holding that a statute must be construed so that no part of the statute is rendered surplusage or superfluous internal quotation marks and citation omitted holding with respect to a general motion for directed verdict that it raised the question as to the sufficiency of the evidence on venue an essential part of the governments case internal quotation marks and citation omitted holding that under ada discrimination need not be the sole reason for the adverse employment decision but must actually play a role in the employers decision making process and have a determinative influence on the outcome citation internal quotation marks and alterations omitted holding that defendants bear the burden of showing that the challenged act was objectively reasonable citation omitted