Uncertified drug dog was still qualified by track record
The government [just barely] showed that the drug dog and the handler were "well qualified" (Illinois v. Caballes). While the dog was certified through 2006, it was not certified since, but its general reliability was enough. [Essentially, the handler can make the dog qualify by testifying to a good track record.] United States v. Colon-Arenas, 2009 U.S. Dist. LEXIS 77953 (N.D. Ind. August 25, 2009).