M.D.Pa.: Dog alert satisfied CA3 standards because it was to specific place

The search of defendant’s U-Haul truck was justified by a dog alert. “Assuming arguendo that Third Circuit precedent supported defendants’ more taxing standard for what constitutes a positive and reliable alert, Trooper Hoy still had probable cause to search the U-Haul truck because Canine Tom also indicated to the specific location of the narcotics.” United States v. Xiao Wu Zhou, 2019 U.S. Dist. LEXIS 130934 (M.D. Pa. Aug. 6, 2019).

Defendant’s order for lifetime satellite based monitoring is reversed, knowing that the issue is pending before the state supreme court in other cases. State v. Tucker, 2019 N.C. App. LEXIS 640 (Aug. 6, 2019).*

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