Traffic Stop; Reliability Foundation; Alert; Final Indication
PSD team called to scene to sniff UHaul truck. PSD showed intense interest in passenger side wheel well. When redirected, PSD stopped at the rear passenger side of the cargo area and stared at it, jaws quivering. Handler could not get him to move. Cargo area searched and 735 pounds of marijuana found. Defense expert tried to convince the court that this was not alert behavior, just a dog being a dog. However, when asked, the defense expert said the handler should not have ignored this behavior and conceded PSDs behavior consistent with overwhelming amount of scent. Court held PSDs actions constituted an alert and therefore probable cause.