Page:Jackson v. State, 2013 Ark. 201, 427 S.W.3d 607.pdf/12

 other dog trainers, with the consultation of the German police. Corporal Behnke also stated that he and K-9 Major conduct training throughout the year to make sure they stay proficient. Although Jackson put forth some evidence regarding false alerts by K-9 Major, the circuit court, after hearing testimony about Corporal Behnke and K-9 Major's training, ruled the dog was reliable. In light of the ruling in Harris, ___ U.S. ___, 133 S. Ct. 1050, we cannot say this was clearly erroneous.

We also cannot say that the circuit court erred in finding that Corporal Behnke had probable cause to search the vehicle based on the alert by K-9 Major. Corporal Behnke testified that when dealing with K-9 Major there can be an alert, a profound alert, or an indication. He explained that an alert is a change in behavior that the handler knows and can recognize upon his own canine. He also testified that a profound alert is something that any human being, by sitting there and watching him, can understand that the dog has had a significant change in behavior. Finally, an indication, he explained, will either be a sit, stand, or lay. In this instance, Corporal Behnke stated that K-9 Major demonstrated a profound alert. More specifically, he stated that after conducting the free-air sniff, K-9 Major began pulling him toward the front-passenger side of the vehicle, to the point the dog was almost choking himself. According to Corporal Behnke, the dog's behavior changed in that he exhibited excessive tail wagging and deep, labored breathing. As they neared the front of the vehicle, Corporal Behnke stated that K-9 Major turned to begin the detailed sniff, returned down the driver's side of the vehicle, and as they approached the rear tire, the dog stopped, turned back around, and began to sniff in the open driver's side window. According to