police officer is considered the employee of the applicant for the commission, § 4-909, and is generally limited to exercising police powers on the property. Huger v. State, 285 Md. 347, 352, 402 A.2d 880 (1979). Nevertheless, the police power itself is not so limited since the words “peace and good order,” contained in the statute, “ ‘permit a special policeman, when on his employer’s property, to enforce the criminal law generally.’ ” Id. at 351, 402 A.2d 880, quoting Gray v. State, 38 Md.App. 343, 349, 380 A.2d 1071 (1977), cert, denied, 282 Md. 732 (1978). When special police officers are enforcing the criminal law, they are exercising governmental powers which involve state action. See, e.g., Griffin v. Maryland, 378 U.S. 130, 135, 84 S.Ct. 1770, 1772, 12 L.Ed.2d 754 (1964) (<HOLDING>). Griffin involved special deputy sheriffs,
holding that if an individual is possessed of state authority and purports to act under that authority his action is state action holding that the state police is a state agency holding authority to transfer every asset of failed bank includes authority to transfer choses in action not assignable under state law holding that the district court was not required to state affirmatively on the record that it knew it possessed the authority to depart downward holding that while the fourteenth amendment is directed against state action and not private action the state action requirement is met in a civil action where state law is applied whether by statute or common law