The State charged Petitioner Clayton Harris with possession of pseudoephedrine with the intent to manufacture methamphetamine, in violation of state law. On a traffic stop, officers noticed that Petitioner was "shaking, breathing rapidly, and could not sit still." When Petitioner did not consent to a search of his vehicle, officers brought over their drug-sniffing dog to conduct a "free sniff" of the exterior of the vehicle. The dog alerted to the smell of drugs on the driver's side door. Using the alert as the basis of a warrantless search of the interior, officers discovered pseudoephedrine under the driver's seat and 8 boxes of matches. Petitioner was placed under arrest, and after being read his Miranda rights, stated that he had been cooking meth at least two weeks prior to this traffic stop. At trial, the State argued that the arresting officer had probable cause based on his observations from the stop: an expired plate-tag, Petitioner's nervousness, and an alert from a trained drug-sniffing dog. Petitioner challenged the dog's reliability. The trial court denied the motion to suppress, found that there was probable cause to search Petitioner's vehicle, and admitted all physical evidence seized. The Supreme Court granted discretionary review to resolve a conflict between the district courts on whether a drug-sniffing dog's alert to its handler can provide probable cause to conduct a warrantless search of the interior of a vehicle. The Court held that the dog's alert alone is not enough; the State must present evidence of the dog's training and certification records; the trial court must assess the reliability of the dog's detection. In this case, the Court reviewed the totality of the circumstances to find that the trial court should have granted Petitioner's motion to suppress; the Court remanded this case for further proceedings.