The supreme court ruled in bureau v. mcdowell that apply/applies only to the actions of government agents and not to those of private citizens or private security employees.

Unlawful search and seizure, the Supreme Court Ruling found that incriminating materials given to government representatives by private citizens or employees do not have the same rules regarding lawful search and seizure. For example, if someone provides incriminating documents that were procured without a search warrant and that someone is a private citizen, these documents are admissible in court and not subject to the same search and seizure laws as if they were being collected by a police officer.