Florida v. Harris

After stopping Harris (defendant) for an expired license plate and noticing his visible nervousness, Officer Wheetley walked his trained narcotics dog, Aldo, around the truck; Aldo alerted at the driver's door, leading Wheetley to find pseudoephedrine, matches, hydrochloric acid, antifreeze, and iodine crystals -- all methamphetamine-making ingredients. Harris moved to suppress the evidence, arguing the officer lacked probable cause; the state presented evidence of Wheetley's and Aldo's extensive training and Aldo's strong performance in training exercises, though it lacked complete records of Aldo's field performance, including any false positives. The trial court denied suppression, but the Florida Supreme Court reversed, holding the state needed to produce field-performance records to establish the dog's reliability, and Florida sought review.