Generally, “the common law presumption of regularity, that a properly stamped, addressed and mailed envelope is presumed to have been received by the addressee, applies to ordinary first class mail.”1 The presumption is “founded upon the probability that the officers of the government will do their duty, in the usual course of business.”2 But wait a minute, Mr. Postman. If the presumption is based upon the usual course of business of the post office, then it stands to reason that the legal standard to raise such presumption would vary based upon the method of mailing chosen by the sender.

The U.S. Postal Service (USPS) offers myriad mailing methods beyond ordinary first class mail that may be selected by the sender. Pursuant to the USPS Domestic Mail Manual, these methods are considered to be an “extra service” and require a supplemental charge as these methods of mailing require additional steps beyond that of ordinary first class mail.3