Search: probable cause: dog: Officer Wheetley executed a sniff test with his trained narcotics dog, Aldo. The dog alerted at the driver’s-side door handle, leading Wheetley to conclude that he had probable cause for a search. That search turned up nothing Aldo was trained to detect, but did reveal pseudoephedrine and other ingredients for manufacturing methamphetamine; suppression hearing; because training and testing records supported Aldo’s reliability in detecting drugs and Harris failed to undermine that evidence, Wheetley had probable cause to search Harris’s truck; in testing whether an officer has probable cause to conduct a search, all that is required is the kind of “fair probability” on which “reasonable and prudent people act.” Illinois v. Gates, 462 U. S. 213, 235. To evaluate whether the State has met this practical and common-sensical standard, this Court has consistently looked to the totality of the circumstances and rejected rigid rules, bright-line tests, and mechanistic inquiries; such inaccuracies do not taint records of a dog’s performance in standard training and certification settings, making that performance a better measure of a dog’s reliability. Field records may sometimes be relevant, but the court should evaluate all the evidence, and should not prescribe an inflexible set of requirements.
Under the correct approach, a probable-cause hearing focusing on a dog’s alert should proceed much like any other, with the court allowing the parties to make their best case and evaluating the totality of the circumstances (U.S. S. Ct., 19.02.13, Florida v. Harris, J. Kagan, unanimous).