In Florida v. Harris (2013) U.S., 133 S.Ct. 1050, Harris's attorney challenged the canine's certification and performance in the field. (Id. at p. 1054.) The trial court disagreed, and found that the officer did have probable cause to search the defendant's truck. (Ibid.) On appeal, the Florida Supreme Court reversed, holding that " 'When a dog alerts,' . . . 'the fact that the dog has been trained and certified is simply not enough to establish probable cause.' " (Id. at p. 1055.) The United States Supreme Court granted certiorari, and on February 19, 2013, after appellant's opening brief was filed in this case, a unanimous court overturned the Florida Supreme Court's holding. The court opined that the Florida Supreme Court's requirement for assessing the reliability of a drug-detection dog "flouted the established approach to determining probable cause." (Harris, supra, 133 S.Ct. at p. 1056). In its ruling, the Supreme Court specifically addressed the issue of dog alerts to residual odors in footnote 2, explainin: "The Florida Supreme Court treated a dog's response to residual odor as an error, referring to the 'inability to distinguish between such odors and actual drugs' as a 'factor that calls into question the canine's reliability. ' But that statement reflects a misunderstanding. A detection dog recognizes an odor, not a drug, and should alert whenever the scent is present, even if the substance is gone (just as a police officer's much inferior nose detects the odor of marijuana for some time after a joint has been smoked). In the usual case, the mere chance that the substance might no longer be at the location does not matter; a well-trained dog's alert establishes a fair probability--all that is required for probable cause--that either drugs or evidence of a drug crime (like the precursor chemicals in Harris's truck) will be found." (Id. at pp. 1056-1057, fn. 2.)