To demonstrate that an officer has a reasonable basis for believing that an alert by a drug detection dog is sufficiently reliable to provide probable cause to search, the State must present evidence of the dog‘s training and certification records, an explanation of the meaning of the particular training and certification, field performance records (including any unverified alerts), and evidence concerning the experience and training of the officer handling the dog, as well as any other objective evidence known to the officer about the dog‘s reliability. The trial court must then assess the reliability of the dog‘s alert as a basis for probable cause to search the vehicle based on a totality of the circumstances.
In reversing the Florida Supreme Court judgment, the Supreme Court synthesized and concluded in Florida v. Harris that:
The question—similar to every inquiry into probable cause—is whether all the facts surrounding a dog’s alert, viewed through the lens of common sense, would make a reasonably prudent person think that a search would reveal contraband or evidence of a crime. A sniff is up to snuff when it meets that test. And here, Aldo’s did. The record in this case amply supported the trial court’s determination that Aldo’s alert gave Wheetley probable cause to search Harris’s truck.Photo credit: www.puppyloveandme.com