but observed in dictum that “[a]lthough the BIA has directed us to review the IJ’s opinion in streamlined cases, deferring to the reasoning of an IJ from which the BIA would be free to depart in other cases would seem highly problematic.” 387 F.3d 279, 289 n. 6 (3d Cir.2004). No consensus exists among our sister Courts of Appeals as to what quantum of deference, if any, should be accorded to these opinions. After Mead, several Courts of Appeals affirmatively rejected application of Chevron deference to unpublished BIA decisions. See Quinchia v. Att’y Gen., 552 F.3d 1255, 1258 (11th Cir.2008) (stating that an unpublished BIA decision that does not rely on BIA or Court of Appeals precedent does not receive Chevron deference); Rotimi v. Gonzales, 473 F.3d 55, 57-58 (2d Cir.2007) (<HOLDING>) (internal quotation marks omitted);
holding that an unpublished bia decision that does not rely on precedent for its definition of a contested term does not receive chevron deference because it is not promulgated under the agencys authority to make rules carrying the force of law holding that because the fcc is authorized to promulgate binding legal rules and it issued the order under review in the exercise of that authority its interpretation of the communications act was entitled to chevron deference holding that chevron deference is due only when the agency acts pursuant to delegated authority and the agency action has the force of law holding chevron deference is required for a precedential threemember decision of the bia but is not appropriate for a nonprece dential singlemember decision that does not rely on existing bia or federal court precedent holding that administrative implementation of a particular statutory provision qualifies for chevron deference when it appears that congress delegated authority to the agency generally to make rules carrying the force of law and that the agency interpretation claiming deference was promulgated in the exercise of that authority