In State v. Nguyen, 2007 SD 4, 726 N.W.2d 871, 876-77 (S.D. 2007), the defendant asserted that the dog's field activity report reflected the dog's unreliability.
The South Dakota Supreme Court stated that while the "apparently false indications gave it pause, . . . it did not believe these field reports should be relied on, standing alone, in measuring the dog's reliability." Id. at 877.
The court explained:
"In our view, trial courts making drug dog reliability determinations may consider a variety of elements, including such matters as the dog's training and certification, its successes and failures in the field, and the experience and training of the officer handling the dog. Under the totality of the circumstances, the court can then weigh each of these factors." Id.