Sniff as Probable Cause; Pretext Search
LE executed a search warrant on a bail bonds business for business records in a criminal investigation. There was no basis in the search warrant nor any authorization to search for controlled substances. A PSD was present along with its handler. Court held since there were no controlled substances found, there was no harm to the person who was the subject of the search warrant. However, this case should serve as a warning that using an investigation as a pretext to have a PSD present to perform sniffs for controlled substances will be frowned on.