Whether the police may conduct a warrantless search for drugs based solely on an alert by a drug-sniffing dog without any other evidence of the dog's reliability so long as the dog has been "trained" or "certified."

An increasing body of evidence has shown that even dogs that have been trained to detect drugs have wildly varying degrees of success in actually detecting drugs. The question in this case is whether any alert by a “trained” dog is sufficient to establish probable cause or whether, as the ACLU argues in its amicus brief, the police must establish the dog’s reliability in order to justify a warrantless search.

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