What's the lowest form of dicta?

This 2/6 pub'd opinion here has a potentially useful line for appellate lawyers at page 7, noting that the "lowest form of dicta" is "footnote dicta." (See also U.S. v. Bahadar (2d Cir. 1992) 954 F.2d 821.) The opening paragraph is good too: "A cause of action survives one year after the death of a debtor. But not a judgment lien. Judgment liens have longevity."
(The MetNews's coverage is here.)