Florida v. Harris Case Brief

Facts of the Case

Officer Wheetley pulled over respondent Harris for a routine traffic stop. Observing Harris’s nervousness and an open beer can, Wheetley sought consent to search Harris’s truck. When Harris refused, Wheetley executed a sniff test with his trained narcotics dog, Aldo. The dog alerted at the driver’s-side door handle, leading Wheetley to conclude that he had probable cause for a search. That search turned up nothing that Aldo was trained to detect but did reveal pseudoephedrine and other ingredients for manufacturing methamphetamine. Harris was arrested and charged with illegal possession of those ingredients. In a subsequent stop while Harris was out on bail, Aldo again alerted on Harris’s truck but nothing of interest was found. At a suppression hearing, Wheetley testified about his and Aldo’s extensive training in drug detection. Harris’s attorney did not contest the quality of that training, focusing instead on Aldo’s certification and performance in the field, particularly in the two stops of Harris’s truck. The state trial court denied the motion to suppress, but the Florida Supreme Court reversed. It held that a wide array of evidence was always necessary to establish probable cause, including field performance records showing how many times the dog has falsely alerted. If an officer like Wheetley failed to keep such records, he could never have probable cause to think the dog a reliable indicator of drugs. The State sought certiorari review.




“Yes. Justice Elena Kagan, writing for a unanimous court, reversed the Florida Supreme Court. The U.S. Supreme Court rejected the lower court’s rigid requirement that police officers show evidence of a dog’s reliability in the field to prove probable cause. Probable cause is a flexible common sense test that takes the totality of the circumstances into account. A probable cause hearing for a dog alert should proceed like any other, allowing each side to make their best case with all evidence available. The record in this case supported the trial court’s determination that police had probable cause to search Harris’ car.Learn more about the Roberts Court and the Fourth Amendment in Shifting Scales , a nonpartisan Oyez resource.”

Case Information

Citation: 568 US 237 (2013)
Granted: Mar 26, 2012
Argued: Oct 31, 2012
Decided: Feb 19, 2013
Case Brief: 2013