Arizona Mail Delivery Rule
In Lee v. State, 218 Ariz. 235, 182 P.3d 1169 (2008), the Arizona Supreme Court summarized the common-law mail delivery rule:
We have long recognized what is best termed a "mail delivery rule." This common law rule has two components: one a presumption, and one a rule regarding the sufficiency of evidence.
Under the mail delivery rule, there is a presumption that a "letter properly addressed, stamped and deposited in the United States mail will reach the addressee."
That is, proof of the fact of mailing will, absent any contrary evidence, establish that delivery occurred.
If, however, the addressee denies receipt, the presumption of delivery disappears, but the fact of mailing still has evidentiary force.
The denial of receipt creates an issue of fact that the factfinder must resolve to determine if delivery actually occurred. 218 Ariz. at 237,8, 182 P.3d at 1171.