the conditions of Karam’s OR release — requiring that she obtain permission of the court before leaving the state and that she make court appearances — amounted to a seizure under the Fourth Amendment. We conclude they did not. There is a division of circuit authority as to what may constitute a seizure under the Fourth Amendment in the context of pretrial release. Some courts have held that a seizure occurs only when there is an actual detention. See, e.g., Riley v. Dorton, 115 F.3d 1159, 1164 (4th Cir.1997) (rejecting concept of seizure occurring during pretrial release); Wilkins v. May, 872 F.2d 190, 194 (7th Cir.1989) (same). Other circuits have concluded that some pre-trial release restrictions may qualify as a seizure. See Evans v. Ball, 168 F.3d 856, 860-61 (5th Cir.1999) (<HOLDING>); Gallo v. City of Philadelphia, 161 F.3d 217,
holding a combination of pretrial release restrictions including restriction on interstate travel amount to a seizure recognizing that  the interstate nexus requirement is satisfied by proof of a probable or potential impact on interstate commerce holding that under a similar statute the government need only show that the defendant had the intent to carry on illegal activity and that the crime occurred in conjunction with interstate travel holding that inperson reporting requirements in iowa sex offender registry statute did not infringe on right to interstate travel holding that a quick look analysis was inappropriate for restrictions imposed by professional association of dentists on member advertising where the likelihood of noncompetitive effects of restrictions were not obvious and restrictions could plausibly be thought to have procompetitive effect on competition