Is repossession of property by a private individual not a state action?

MultiRegion, United States of America

The following excerpt is from Howerton v. Gabica, 708 F.2d 380 (9th Cir. 1983):

At some point, as police involvement becomes increasingly important, repossession by private individuals assumes the character of state action. This is explained in Harris v. City of Roseburg, 664 F.2d 1121, 1127 (9th Cir.1981): 7

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