Is the presumption of three-day mail receipt still valid given changes in the postal system?

Is the presumption in kerr of getting legal mail in 3 days is out of date? Kerr v. McDonald ’s Corp., 427 F.3d 947, 953 n.9 (11th Cir. 2005).. Courts apply a presumption of three days for receipt by mail. BUT the mail system has permanently changed. And petitioners have solid proof. This court ’s own mail was late being sent to the cichowskis. Tracking number