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Florida v. Harris

United States Supreme Court
133 S.Ct. 1050 (2013)


Facts

Officer William Wheetley pulled over Clayton Harris (defendant) because Harris’s truck had an expired license plate. Wheetley noted that Harris was visibly nervous, unable to sit still, shaking, and breathing rapidly. Wheetley walked his K-9, Aldo, around the truck. Aldo was a German shepherd trained to detect narcotics. Aldo alerted at the driver-side door handle, signaling that he detected drugs. Wheetley discovered 200 loose pseudoephedrine pills, 8,000 matches, a bottle of hydrochloric acid, two containers of antifreeze, and a coffee filter full of iodine crystals, all ingredients for making methamphetamine. The State of Florida (plaintiff) charged Harris with possessing pseudoephedrine for use in manufacturing methamphetamine. Harris moved to dismiss the evidence found in his truck, alleging that Wheetley did not have probable cause to search the vehicle. The state introduced evidence regarding the training of both Wheetley and Aldo in detecting the presence of drugs. The evidence showed that they had completed significant training and specific courses regarding the detection of drugs and that Aldo performed well in training exercises. However, the state did not maintain complete records of Aldo’s performance in the field, like false positives. The trial court denied the motion to suppress, and Harris entered a no-contest plea that reserved his right to appeal the ruling. Harris appealed, and the Florida Supreme Court reversed, holding that the state must present field-performance records to establish a drug dog’s reliability. The state petitioned the United States Supreme Court for review.

Rule of Law

Issue

Holding and Reasoning (Kagan, J.)

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