In what circumstances will the court suppress evidence from a private security guard in a civil case?

The People contend the trial court erred in suppressing evidence under People v. Zelinski (1979) 24 Cal.3d 357, 155 Cal.Rptr. 575, 594 P.2d [227 Cal.App.3d 1570] 1000, in that the case has been superseded by the adoption of article I, section 28, subdivision (d), of the California Constitution, and it is no longer required that evidence seized by privately employed security personnel, who are acting on their own initiative and are not instruments or agents of the state, be excluded. For the reasons set forth below, we agree.

In People v. Zelinski, supra, 24 Cal.3d 357, 155 Cal.Rptr. 575, 594 P.2d 1000, store detectives arrested defendant for shoplifting, searched her purse for stolen merchandise and discovered a vial of heroin; she was then taken into police custody and charged with unlawful possession of heroin. (At p. 361, 155 Cal.Rptr. 575, 594 P.2d 1000.) The court concluded the search of her purse was illegal; the question then was whether the fruit of that search--the vial of heroin--must be excluded. (Id. at p. 364, 155 Cal.Rptr. 575, 594 P.2d 1000.)