We hold 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. To demonstrate that an officer has a reasonable basis for believing that an alert by a drug-detection dog is sufficiently reliable to provide probable cause to search, the State must present evidence of the dog‘s training and certification records, an explanation of the meaning of the particular training and certification, field performance records (including any unverified alerts), and evidence concerning the experience and training of the officer handling the dog, as well as any other objective evidence known to the officer about the dog‘s reliability. The trial court must then assess the reliability of the dog‘s alert as a basis for probable cause to search the vehicle based on a totality of the circumstances.
Page 40 , Harris v. State (Florida Supreme Court, 21 April 2011,SC08-1871)