CA8: Alert style not specified by court to be upheld
United States v. Collier, 2024 U.S. App. LEXIS 22709 (8th Cir. Sep. 6, 2024). "Every dog is unique, and a dog that smells illicit drugs is not required to communicate with its handler in any specific way. … ‘Dogs alert in many different manners. One dog may alert in one manner while another dog may alert in another manner.’ … The reliability of a dog’s alert, not its manner, is what matters. See Holleman, 743 F.3d at 1156 (‘Fourth Amendment jurisprudence does not require drug dogs to abide by a specific and consistent code in signaling their sniffing of drugs [...]