Page:Jackson v. State, 2013 Ark. 201, 427 S.W.3d 607.pdf/11

 use effective training and certification programs, because only accurate drug-detection dogs enable officers to locate contraband without incurring unnecessary risks or wasting limited time and resources.

Id. at ___, 133 S. Ct. 1057.

Remaining mindful of the Supreme Court's holding in Harris, we cannot say that there are any specific evidentiary items that will demonstrate, or necessarily refute, a drug dog's reliability. As with other issues that arise when one seeks to suppress evidence from a search and seizure, it is the circuit court that will be the ultimate arbiter of credibility. E.g., Cockrell, 2010 Ark. 258, 370 S.W.3d 197.

Here, in arguing that K-9 Major was not reliable, Jackson points to testimony calling into question the canine's track record, including the fact that K-9 Major, in 2011, alerted on vehicles with a no-find at a rate of fourteen percent. According to Jackson, this percentage is not reliable enough to establish probable cause, and when considered with the fact that the dog did not give a final indication, it was error for the circuit court to deem the dog reliable when determining whether probable cause existed. We disagree.

Corporal Behnke testified that K-9 Major is trained to detect marijuana, cocaine, heroin, methamphetamine, and ecstasy. He explained that he and K-9 Major were trained by Arkansas State Police Canine Coordinator, Roby Rhoads. There were also three certifications related to Corporal Behnke's and K-9 Major's training introduced into evidence, including completion of the PSP-1, Police Dog Critical Skills Test; and the Narcotics Detector Dog Team PSP-2, Police Scenting Dog Test. Corporal Behnke explained that the PSP-2 is the standard used by the Arkansas State Police and was developed by behaviorists and