Florida v. Harris
133 S. Ct. 1050
| SCOTUS | 2013Background
- Harris was stopped for an expired license plate; Aldo, a narcotics-detection dog, alerted at the driver’s-side door after a free-air sniff.
- Search based on Aldo’s alert yielded meth ingredients but no drugs; Harris was arrested for possessing those ingredients.
- A second stop with Aldo again alerted but produced nothing; Harris challenged the stop's legality via suppression motion.
- Harris’s trial evidence focused on Aldo’s field performance; the Florida Supreme Court required extensive field records and certification history to establish reliability.
- The Florida Supreme Court held that without field-performance records, probable cause could not be shown, effectively creating a strict evidentiary checklist.
- The U.S. Supreme Court reversed, holding that training or certification evidence, along with other proof, can establish probable cause under a totality-of-the-circumstances approach.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Florida's evidentiary checklist is compatible with totality-of-circumstances. | Harris argued the checklist is not required; rely on totality of evidence. | Florida insisted on a comprehensive field-record checklist to prove reliability. | Florida checklist rejected; totality-of-evidence governs probable cause. |
| Can training/certification records alone establish probable cause for a dog's alert? | Records insufficient to demonstrate reliability without field data. | Training/certification evidence suffices to trust the alert. | Yes; certified or recently trained dogs can provide probable cause absent contrary evidence. |
| Must a defendant be allowed to challenge the dog's reliability in court? | Defendant should have opportunity to challenge reliability. | State’s proof of training should stand unless challenged. | Defendant must be allowed to challenge reliability; court weighs all evidence. |
Key Cases Cited
- Illinois v. Gates, 462 U. S. 213 (1983) (adopts totality-of-the-circumstances approach for probable cause)
- Maryland v. Pringle, 540 U. S. 366 (2003) (probable-cause standards not highly precise)
- United States v. Di Re, 332 U. S. 581 (1948) (probable cause not measured by hindsight)
- Brinegar v. United States, 338 U. S. 160 (1949) (probable cause evaluated with practical, common-sense standards)
- Carroll v. United States, 267 U. S. 132 (1925) (early probable-cause framework for search of vehicles)