in which Heck’s holding does not absolutely foreclose a claim. See, e.g., Burd v. Sessler, 702 F.3d 429, 435-36 (7th Cir.2012); Cohen v. Longshore, 621 F.3d 1311, 1317 (10th Cir.2010); Wilson v. Johnson, 535 F.3d 262, 267-68 (4th Cir.2008); Powers v. Hamilton Cnty. Public Defender Comm’n, 501 F.3d 592, 603 (6th Cir.2007); Guerrero v. Gates, 442 F.3d 697, 704 (9th Cir.2006); Harden v. Pataki, 320 F.3d 1289, 1298 (11th Cir.2003). But even the courts that recognize certain narrow exceptions to Heck emphatically reject the idea that the rule in Heck no longer applies once a convict exits the prison gates. The Seventh Circuit, for instance, recently dismissed a claim by a released convict who argued that § 1983 must be made available if habeas relief is not. See Burd, 702 F.3d at 435-36 (<HOLDING>). Likewise the Ninth Circuit: “The fact that [a
holding that res judicata is not applicable to a claim for relief that was unavailable in the earlier action holding that heck applies to bivens claims holding that plaintiffs who sought injunctive relief under 42 usc  1983 could get same relief in a state court mandamus action holding that collateral estoppel applies to  1983 claims holding that heck applies where a  1983 plaintiff could have sought collateral relief at an earlier time but declined the opportunity and waited until collateral relief became unavailable before suing