In addition, the district court explicitly rejected the BIA’s holding in Matter of Saysana that INA § 236(c) applies even when released from custody for a non-removable offense. 24 I&N Dec. 609 (BIA 2008). DHS argued that the district court was required to defer to the BIA’s interpretation under Chevron USA, Inc. v. Natural Resources Defense Council, Inc., the Supreme Court decision that requires courts to defer to agency interpretations of a statutory provision that falls within the agency’s area of expertise (as the BIA has over the INA) when that statutory provision is unclear and the agency’s interpretation is reasonable.