## Facts

- In 1984, Victor Townes rode as a passenger in a livery taxicab with two companions traveling from the Bronx to Manhattan.
- Plainclothes NYPD officers in an unmarked car watched Townes; while in the cab, he hid two loaded handguns under the front and passenger seats.
- The officers stopped the cab without probable cause, ordered Townes out, and searched him; nothing was found on his person.
- The officers searched the cab, found the two loaded handguns, arrested Townes, and took him to a police station.
- During a later search at the station, officers found cocaine in Townes’s pocket.
- Townes was prosecuted and convicted on weapons and drug charges; the trial court denied his motion to suppress the physical evidence.
- On direct appeal, a state appellate court held the stop and searches unconstitutional, ruled the evidence should have been suppressed, and reversed Townes’s convictions after he had been imprisoned for more than two years.
- Townes then sued the officers and the City under 42 U.S.C. § 1983, seeking damages primarily for his arrest, conviction, and incarceration; the district court denied qualified immunity, and Townes’s state-law claim was dismissed as time-barred.

## Issues

1. Whether Townes could recover § 1983 damages for his conviction and incarceration as consequences of an unlawful stop and search.
2. Whether incarceration and conviction are compensable injuries in a § 1983 action premised on a Fourth Amendment search-and-seizure violation.
3. Whether the court of appeals had jurisdiction to consider Townes’s cross-appeal challenging dismissal of his state-law claim in an interlocutory qualified-immunity appeal.

## Decision

- The court reversed the denial of qualified immunity and directed dismissal of Townes’s § 1983 claims seeking damages for conviction and incarceration.
- The court held that, even assuming a clearly established Fourth Amendment violation, Townes’s claimed injuries (conviction and imprisonment) were not legally caused by the unlawful stop and search.
- The trial court’s independent decision denying suppression constituted an intervening, superseding cause that broke the chain of § 1983 causation for those downstream injuries.
- The court dismissed Townes’s cross-appeal for lack of appellate jurisdiction.

## Legal Principles

- A § 1983 plaintiff must show proximate causation; an intervening exercise of independent judgment by a court can be a superseding cause that cuts off liability for later harms.
- The exclusionary rule and “fruit of the poisonous tree” doctrine are criminal-procedure remedies and do not automatically translate into civil damages liability under § 1983.
- Fourth Amendment damages generally compensate for the privacy and liberty invasion of an unreasonable search or seizure itself, not for conviction and incarceration attributable to a later judicial ruling admitting evidence.

## Conclusion

The court held that an unconstitutional stop and search did not permit § 1983 recovery for conviction and imprisonment when the evidence was admitted at trial due to a court’s independent (though later reversed) suppression ruling, which severed causation for those claimed damages.


Townes v. City of New York, 176 F.3d 138 (2d Cir. 1999)