paper trail shows mailing, and either receipt or nonreceipt, thereby supplying “documentary evidence from the Postal Service.” Grijalva, 21 I. & N. Dec. at 37; accord Sembiring, 499 F.3d at 987. The close fit between the evidence required to rebut the presumption of receipt and the evidence produced from using certified mail led one circuit to observe that Grijalva’s evidentiary requirements “ma[ke] perfect sense in connection with certified mail.” Salta v. INS, 314 F.3d 1076, 1080 (9th Cir.2002). And because certified mail is very likely to be delivered to the address that it is mailed to, the BIA’s interpretation of § 1252b(e)(3)(B) is a reasonable one. We therefore defer to that interpretation. See INS v. Aguirre-Aguirre, 526 U.S. 415, 424-25, 119 S.Ct. 1439, 143 L.Ed.2d 590 (1999) (<HOLDING>); Patel v. Gonzales, 432 F.3d 685, 692 (6th
holding that the ninth circuit erred by failing to defer to the bias reasonable interpretation of the ina holding that a court should afford deference to the bias interpretation if reasonable of the phrase aggravated felony set forth in the ina but the court should review de novo the bias determination of whether the elements of a statelaw conviction met that interpretation holding that circuit court should defer to supreme courts interpretation of the act holding that the ninth circuit is bound by the california supreme courts interpretation of california law holding that the ninth circuit erred in requiring arizona courts to conduct a jury trial to resolve mentalretardation claim