Whether Mervin's positive alert on a parcel shipped to Hawaii, given his unsophisticated training and the possibility of contamination, suffices to establish probable cause to issue a warrant to search the parcel

QUESTION PRESENTED Police trained Mervin, a drug-detection canine, to alert on minimal residual odor. In accord with that training, Mervin often alerted on parcels containing no contraband drugs, which police officers, testifying as experts, opined was most likely explained by the parcels having been contaminated by residual drug odor on their way to Hawaii. Such proximity, this Court has held in other contexts, does not give rise to probable cause. The question presented here is whether Mervin’s positive alert on a parcel shipped to Hawaii, given his unsophisticated training and the possibility of contamination, suffices to establish probable cause to issue a warrant to search the parcel.