In People v. Zelinski (1979) 24 Cal.3d 357, private security personnel working as store detectives observed defendant place a blouse in her purse; outside of the store they arrested her; they returned her to the store to await police, and in the security office conducted a routine search for weapons which led to the discovery of narcotics. (Pp. 360-361.) The court concluded "that the narcotics evidence was obtained by unlawful search and that the constitutional prohibition against unreasonable search and seizure affords protection against the unlawful intrusive conduct of these private security personnel." (P. 362.) Zelinski expressly recognized the difference between the activities of security personnel and those of ordinary private citizens.