would qualify as an actionable § 1983 injury. Id. Our decision in this case rests largely upon how we interpret footnote seven. At one point, there were two dominant approaches to the question of whether Fourth Amendment claims are subject to the Heck deferral rule. E.g., Harvey v. Waldron, 210 F.3d 1008, 1015 (9th Cir.2000) (noting that “[t]here is a split in the circuits as to how Heck’s footnote seven should be interpreted.”); Shamaeizadeh v. Cunigan, 182 F.3d 391, 395 (6th Cir.1999). Some courts had interpreted footnote seven as categorically excluding Fourth Amendment claims from the Heck deferred accrual rule. Under this approach, Fourth Amendment claims for unreasonable searches are not deferred under Heck. See, e.g., Nieves v. McSweeney, 241 F.3d 46, 52 (1st Cir.2001) (<HOLDING>); Copus v. City of Edgerton, 151 F.3d 646, 648
holding that false arrest is one means of committing false imprisonment holding that a cause of action for illegal arrest and false imprisonment accrued at the time plaintiff was released from his alleged illegal restraint and not when the proceedings by which his arrest occurred terminated holding that claims for false arrest and imprisonment under  1983 accrue at the time of the arrest holding that false arrest and false imprisonment claim were not duplicative holding that because there was probable cause for arresting plaintiff plaintiffs claims whether under section 1983 or new york state law that were predicated on false arrest or false imprisonment compelled dismissal