United States v. Goldberg 2021 U.S. App. LEXIS 7431 (10th Cir. Mar. 15, 2021) U.S. Court of Appeals Tenth Circuit To the extent that Goldberg brings a legal challenge, this court has held that an alert, as opposed to a final indication, is sufficient to establish probable cause. See Moore, 795 F.3d at 1232 (“We have held that an alert, or a change in a dog’s behavior in reaction to the odor of drugs, is sufficient to establish probable cause to search a vehicle, and that a final indication is not necessary.”); Parada, 577 F.3d at 1282 This [...]

United States v Parada (577 F. 3d 1275 (2009) U.S. Court of Appeals Tenth Circuit) Holding that "officers had probable cause to search the entire vehicle based on the dog's alert to the front driver's side door" One of our early dog sniff cases assumed without deciding that the police had only reasonable suspicion until the dog "keyed," i.e., indicated, the exact location of the drugs whereupon officers had probable cause to search. United States v. Stone, 866 F.2d 359, 364 (10th Cir. 1984). The precise issue raised by Mr. Parada was not before the court in Stone, however, and  our later cases have not [...]