In Oakland Raiders v. National Football League (2007) 41 Cal.4th 624, the California Supreme Court held that, if a trial court fails to file a statement of reasons in support of an order granting a new trial, the burden of persuasion on appeal (which ordinarily falls on the party seeking reversal) is shifted to the party seeking to uphold the trial court's order. (Id. at pp. 640-641.) But that decision was, in the words of the Supreme Court, "a narrow one." (Id. at p. 640.) As the court explained, it "addressed only the situation in which there is conflicting evidence on the issue of juror misconduct, not the question whether misconduct, shown by the record, is prejudicial. The decision did not address the situation in which apparently conflicting declarations can be reconciled, so that on close examination it is determined that the crucial allegations of misconduct are not in dispute." (Ibid.)