A court-approved receiver acting on behalf of a creditor is not a state actor for Fourth Amendment purposes. Wechsler v. Wechsler, 2017 Ida. LEXIS 332 (Dec. 6, 2017):
Norman’s Fourth Amendment claim is meritless. Similar to the trustee in In re Kerlo, who was acting on behalf of the creditors, the Ancillary Receiver was acting on behalf of Sharon. Although the district court appointed the Ancillary Receiver, such appointment does not result in the Ancillary Receiver being an instrument of the government. Indeed, in In re Kerlo the trustee was independent, despite acting according to a court order. The Sheriff’s deputies who were present at the time the Writ was served were only there to assist the Ancillary Receiver; thus, there was no government investigatory purpose. Further, Norman did not have a privacy interest in the property listed in the Writ because he was already required to surrender the information and documents pursuant to the debtor’s examination.