Harris v. State

This case comes before this Court on remand from the decision of the United States Supreme Court in Florida v. Harris, — U.S. -, 133 S.Ct. 1050, 185 L.Ed.2d 61 (2013). In our previous decision, we quashed the First District Court of Appeal’s decision in Harris v. State, 989 So.2d 1214 (Fla. 1st DCA 2008), and held that “the fact that a drug-detection dog has been trained and certified to detect narcotics, standing alone, is not sufficient to demonstrate the reliability of the dog.” Harris v. State, 71 So.3d 756, 775 (Fla.2011). We concluded that “[b]ecause in this case the totality of the…