Florida v.

Harris

Facts of the case

The State of Florida charged Clayton Harris with possession of pseudoephedrine w

ith intent to manufacture methamphetamine. At trial, Harris moved to suppress ev
idence obtained during a warrantless search of his car. Police searched the car
during a traffic stop for expired registration when a drug detection dog alerted
the officer. This dog was trained to detect several types of illegal substances
, but not pseudoephedrine. During the search, the officer found over 200 loose p
ills and other supplies for making methamphetamine. Harris argued that the dog's
alert was false and did not provide probable cause for the search. The trial co
urt denied Harris motion, holding that the totality of the circumstances indicat
ed that there was probable cause to conduct the search. The First District Court
of Appeal affirmed, but the Florida Supreme Court reversed, holding that the St
ate did not prove the dog's reliability in drug detection sufficiently to show p
robable cause.

Question

Does a drug-detection dog's alert to the exterior of a vehicle provide an office

r with probable cause to conduct a warrantless search of the interior of the veh
icle?

Conclusion
Yes. Justice Elena Kagan, writing for a unanimous court, reversed the Florida Su
preme Court. The U.S. Supreme Court rejected the lower court's rigid requirement
that police officers show evidence of a dog's reliability in the field to prove
probable cause. Probable cause is a flexible common sense test that takes the t
otality of the circumstances into account. A probable cause hearing for a dog al
ert should proceed like any other, allowing each side to make their best case wi
th all evidence available. The record in this case supported the trial court's d
etermination that police had probable cause to search Harris' car.