A drug dog sticking his nose into defendant’s car was instinctual and wasn’t caused by the police, following United States v. Sharp, 689 F.3d 616 (6th Cir. 2012). United States v. Miles, 2018 U.S. Dist. LEXIS 66899 (W.D. Ky. Apr. 20, 2018).
The circuit court’s finding that the drug dog was reliable was not clearly erroneous. The officer had probable cause to search defendant’s vehicle because the State presented the most credible and unbiased expert witness, the dog’s training records supported the reliability determination, and the officer’s and the dog’s certifications provided even more support for the reliability finding. The whole of the evidence, including the dog’s training records and field performance, established that the dog was reliable. Grimm v. State, 2018 Md. LEXIS 190 (Apr. 20, 2018).*