There is no absolute defense right to see the full unredacted records of the drug dog\u2019s certification records. United States v. Thomas, 2011 U.S. Dist. LEXIS 45989 (D. Ariz. February 18, 2011):<\/p>\n
Defense counsel objected to the admission of redacted canine certification records on the grounds that the redacted records are insufficient to establish the reliability of the canine team that conducted the search in this case. Counsel cites United States v. Cedano-Arellano, 332 F.3d 568, (9th Cir. 2003), in support of his position. However, in Cedano-Arrellano the trial court had denied the defense motion for any discovery of the canine certification records. The government correctly argues there is precedent in this district for denying a defense request to view unredacted canine certification records and precedent for a court\u2019s reliance on redacted canine certification records.<\/p>\n
This court recommends that the District Court rule that the redacted canine certification reports (Exhibit 2) are admissible and deny the defense motion to discover those unredacted reports. The redacted reports establish the reliability of the canine team.<\/p><\/blockquote>\n
Probable cause and the automobile exception permitted a search under the hood and behind the gas filler door where guns and drugs were found. The defendant had been seen dealing drugs out of the car in the recent past. United States v. Goncalves<\/a>, 642 F.3d 245 (1st Cir. 2011).*<\/p>\n","protected":false},"excerpt":{"rendered":"
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