Can a private party's conduct constitute a governmental action?

MultiRegion, United States of America

The following excerpt is from Chatman v. Acura, Case No.: 3:17-cv-01852-WQH-JLB (S.D. Cal. 2017):

In order for private conduct to constitute governmental action, "something more" must be alleged. Lugar v. Edmondson Oil Co., Inc., 457 U.S. 922, 939 (1982) ("Action by a private party pursuant to [ 1983], without something more, [i]s not sufficient to justify

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