Page:Jackson v. State, 2013 Ark. 201, 427 S.W.3d 607.pdf/9

 Rules of Criminal Procedure, which provides in relevant part that a police officer

"who has reasonable cause to believe that a moving vehicle contains things subject to seizure may, without a search warrant, stop, detain, and search the vehicle and may seize things subject to seizure discovered in the course of the search where the vehicle is:

"(i) on a public way.""

Reasonable cause, as required by this rule, exists when officers have trustworthy information which rises to more than mere suspicion that the vehicle contains evidence subject to seizure and a person of reasonable caution would be justified in believing an offense has been committed or is being committed. E.g., Reyes v. State, 329 Ark. 539, 954 S.W.2d 199 (1997). Here, we are called upon to review whether a positive alert by a canine constitutes sufficient probable cause to search a vehicle.

This court has been presented before with the issue of whether a positive alert from a canine sniff, standing alone, constitutes probable cause to conduct a warrantless search of a vehicle, and we said it does. State v. Thompson, 2010 Ark. 294, 377 S.W.3d 207. There, this court held that where a canine gave a positive alert, there was probable cause for an officer to search a vehicle. In that case, the officer testified as to the dog's reliability and confirmed that his training records had been maintained. Id. This court in deciding Thompson relied on