Florida v. Harris

Summary

The Supreme Court held that whether a drug-detection dog's alert provides probable cause to search a vehicle is judged under the totality of the circumstances, rejecting the Florida Supreme Court's requirement that the State produce an exhaustive evidentiary checklist—including field-performance records—before an alert can count. Evidence of a dog's satisfactory performance in a bona fide certification or training program can by itself justify presuming that the alert establishes probable cause, subject to the defendant's opportunity to challenge the dog's or handler's reliability. Applying that framework, the Court found that Aldo's training record, which Harris never contested in the trial court, established the dog's reliability and gave Officer Wheetley probable cause to search Harris's truck, notwithstanding the expired certification and the absence of complete field-performance records.