reason to search vehicle except at the suggestion of the police). While the agency relationship must be determined from the totality of the cireumstances, see P.E.A., 754 P.2d at 385, we have never held that an agency relationship exists where a defendant has not shown that the private actor lacked an independent motive to conduct the search or was affirmatively encouraged by the government. Applying similar factors, courts in other jurisdictions have routinely recognized that insurance investigators have a motive to investigate an accident seene that is entirely separate from law enforcement's aims. See United States v. Howard, 752 F.2d 220, 228-29 (6th Cir.1985), cert. denied, 472 U.S. 1029, 105 S.Ct. 3506, 87 L.Ed.2d 636 (1985), vacated on other grounds, 770 F.2d 57 (6th Cir.1985) (<HOLDING>); State v. Smith, 40 Conn.App. 789, 673 A.2d
holding that the challenged practices were not consumeroriented under  349 because they were directed only at prospective insurance agents holding that the principal is liable for an agents acts committed within the scope of the agents employment holding that the sca violates the fourth amendment to the extent that it allows government agents to obtain the contents of emails without a warrant holding that insurance investigators were not agents of the government for fourth amendment purposes because they had an independent reason to investigate the scene holding that a canine sniff is a search for purposes of the fourth amendment