What is the test for establishing that a search conducted during search procedures during search and seizure was an intervening and superseding cause of criminal conviction?

10. See, e.g., Townes v. City of New York, 176 F.3d 138, 146 (2d Cir. 1999) (holding, in a suit brought pursuant to 42 U.S.C. 1983, that an illegal search yielding evidence used to convict a criminal defendant was not the proximate cause of the defendant's subsequent conviction and incarceration, because the trial court's refusal to suppress the evidence was an intervening and superseding cause of those events).

10. See, e.g., Townes v. City of New York, 176 F.3d 138, 146 (2d Cir. 1999) (holding, in a suit brought pursuant to 42 U.S.C. 1983, that an illegal search yielding evidence used to convict a criminal defendant was not the proximate cause of the defendant's subsequent conviction and incarceration, because the trial court's refusal to suppress the evidence was an intervening and superseding cause of those events).