How does the Fourth Amendment protect against unreasonable intrusions by private individuals?

"The Fourth Amendment generally does not protect against unreasonable intrusions by private individuals" unless the "private individuals . . . are acting as government instruments or agents." United States v. Reed, 15 F.3d 928, 931 (9th Cir. 1994) (citations omitted). The "mere presence of government agents and their observation of a private person's actions is not significant participation and does not turn a private search into a joint effort." Id. Key to this analysis is "'whether the party performing the search intended to assist law enforcement efforts or further his own ends.'" Id. (quoting United States v. Miller, 688 F.2d 653, 657 (9th Cir. 1982)). "The private searcher must have a legitimate motive other than crime prevention."

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Id. (emphasis original).