Read the following excerpt from a US court opinion:
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Circuits have held that footnote seven creates a general exception to Heck for § 1983 Fourth Amendment unreasonable search and seizure claims. See, e.g., Beck, 195 F.3d at 559 n. 4 (noting that “use of illegally obtained evidence does not, for a variety of reasons, necessarily imply an unlawful conviction,” with the caveat, however, that the case before it was not one of those “rare situation[s] ... where all evidence was obtained as a result of an illegal arrest”); Copus v. City of Edgerton, 151 F.3d 646, 648 (7th Cir.1998) (interpreting Heck’s footnote seven to “mean that Fourth Amendment claims for unlawful searches or arrests do not necessarily imply a conviction is invalid, so in all cases these claims can go forward”); Simmons v. O’Brien, 77 F.3d 1093, 1095 (8th Cir.1996) ; Datz v. Kilgore, 51 F.3d 252, 253 n. 1 (11th
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What is the most suitable continuation to the opinion? Your options are:
A. recognizing that harmless error analysis is appropriate even if presumptively coerced confession is improperly introduced
B. holding the erroneous admission of an involuntary confession is subject to a harmless error analysis when the defendants guilt is established beyond a reasonable doubt
C. holding that even the admission of a coerced confession may be harmless error and noting that  the central purpose of a criminal trial is to decide the factual question of the defendants guilt or innocence 
D. holding that beeause harmless error analysis is applicable to the admission at trial of coerced confessions judgment in favor of simmons on this  1983 action challenging his confession will not necessarily demonstrate the invalidity of his conviction
E. holding admission of coerced confession to he a classic trial error similar in both degree and kind to the erroneous admission of other types of evidence and thus reviewable for harmlessness
Reply with [A, B, C, D, E] only.