State v. McNeal

MORRIS, Judge.

The State appeals an order granting Matthew Wilson McNeal’s motion to suppress. We affirm based on this court’s holding in Matheson v. State, 870 So.2d 8, 14-15 (Fla. 2d DCA 2003), that “the fact that a dog has been trained and certified, standing alone, is insufficient to give officers probable cause to search based on the dog’s alert” and that when making a determination of a dog’s reliability, a trial court must consider several other factors with a particular emphasis placed on the dog’s past performance in the field. However, we previously recognized in both Tedder v.…