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Florida v. Harris
Amicus curiae brief of the National Association of Criminal Defense Lawyers, Florida Ass’n of Criminal Defense Lawyers, the American Civil Liberties Union and the ACLU of Florida in support of the respondent.
Argument: An alert by a “trained” or “certified” drug detection dog by itself is insufficient to establish probable cause; evidence of a dog’s reliability is but one factor in a totality-of-the-circumstances analysis recommended by the Florida Supreme Court. Real-world data demonstrate that even trained or certified dogs have a high rate of false alerts; brief lists a number of different factors relating to a drug dog’s reliability.