With no explanation, chose the best option from "A", "B", "C" or "D". 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,

A: holding a combination of pretrial release restrictions including restriction on interstate travel amount to a seizure
B: recognizing that  the interstate nexus requirement is satisfied by proof of a probable or potential impact on interstate commerce
C: 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
D: holding that inperson reporting requirements in iowa sex offender registry statute did not infringe on right to interstate travel
A.