Moreover, Plaintiff’s Fourth Amendment unlawful arrest and false imprisonment claims cannot be saved by the doctrine of equitable tolling. State law governs whether tolling of the statute of limitations is available to a § 1983 plaintiff whose false imprisonment claim is otherwise time-barred. Wallace, 127 S.Ct. at 1099. Colorado allows for equitable tolling of the statute of limitations in “situations in which either the defendant has wrongfully impeded the plaintiff’s ability to bring the claim or truly extraordinary circumstances prevented the plaintiff from filing his or her claim despite diligent efforts.” Brodeur v. Am. Home Assurance Co., 169 P.3d 139, 149 (Colo. 2007) (citing Dean Witter Reynolds, Inc. v. Hartman, 911 P.2d 1094, 1096 (Colo. 1996)). The rationale for the extraordinary circumstances exception is that “it is unfair to penalize the plaintiff for circumstances outside his or her control, so long as the plaintiff makes good faith efforts to pursue the claims when possible.” Id. The Colorado Supreme Court has never found the requisite “extraordinary circumstances” to exist. See Olson v. State Farm Mut. Auto Ins. Co., 174 P.3d 849, 858 (Colo. App. 2007). Equitable tolling does not apply here. This is not a case where the Supreme Court’s decision in Wallace constituted a change in the law sufficient to effectively deprive the plaintiff of his cause of action. Contrast Kucharski v. Leveille, 526 F. Supp. 2d 768, 775 (E.D. Mich. 2007) (holding that equitable tolling applied to unlawful search claim because strict application of Wallace would effectively deprive the plaintiffs of their cause of action—had the plaintiffs filed their case immediately after the search, Sixth Circuit precedent would have required 24 dismissal of the case as barred by Heck; once the law changed, the plaintiffs would be barred by the statute of limitations under Wallace). In contrast to Sixth Circuit law, the Tenth Circuit has consistently declined to apply the Heck bar to claims challenging the lawfulness of an arrest. Instead, Tenth Circuit law, prior to Wallace, held that “‘[c]laims arising out of police actions toward a criminal suspect, such as arrest, interrogation, or search and seizure, are presumed to have accrued when the actions actually occur.’” Beck, 195 F.3d at 558 (quoting Johnson v. Johnson County Comm’rs Bd., 925 F.2d 1299, 1301 (10th Cir. 1991)); see also Price v. Philpot, 420 F.3d 1158, 1162-63 & n.3 (10th Cir. 2005) (citing Beck). In Beck, which was decided after Heck but before Wallace, the Tenth Circuit held that, with limited exception,8 Heck does not affect the accrual of an action for unlawful arrest because ultimate success on that claim would not necessarily question the validity of the conviction resulting from the charged crime. Beck, 195 F.3d at 558. Beck is consistent with the Supreme Court’s later holding in Wallace that the Heck rule for deferring accrual of a § 1983 cause of action until the criminal conviction is vacated does not apply to claims of false arrest or false imprisonment.9 Wallace, 127 S.Ct. at 1097-98. The law in the Tenth Circuit regarding the date of accrual for an unlawful arrest claim has not changed since at least 1991. Accordingly, this court should reject any argument that the statute of limitations is equitably tolled because Wallace constitutes a recent favorable change in the law precluding the application of Heck to false arrest claims.