The burden then shifts to the defense to produce evidence to challenge the dog's reliability. United States v. Wood 915 F.Supp. 1126, 1134-35 (D.Kan. 1996), rev'd on other grounds, 106 F.3d 942 (10th Cir.1997); State v. Laveroni 910 So.2d 333, 335 (Fla.Ct.App. 2005); Dawson v. State, 238 Ga.App. 263, 518 S.E.2d 477, 479-80 (1999). Third, a minority of jurisdictions either require or allow a dog's field activity reports, along with evidence that the dog is trained and certified, to be considered as factors in determining reliability.

The existence of probable cause is determined by whether, given all the circumstances ..., including the veracity and basis of knowledge of persons supplying hearsay information, there is a fair probability that contraband or evidence of a crime will be found in a particular place.Dawson v. State, 238 Ga.App. 263, 265(1), 518 S.E.2d 477 (1999) (citations and punctuation omitted).Probable cause to search an automobile exists when the facts and circumstances before the officer are such as would lead a reasonably discreet and prudent man to believe that the contents of the vehicle offend the law.

Tate v. State, 264 Ga. 53, 54 (1) ( 440 S.E.2d 646) (1994). "[E]vidence that [a] dog has been trained and certified as a drug detection dog constitutes prima facie evidence of its reliability for purposes of a probable cause determination."Dawson v. State, 238 Ga. App. 263, 267 (1) ( 518 S.E.2d 477) (1999). The State presented evidence that Simba was trained and certified to detect illegal narcotics including methamphetamine, cocaine, marijuana, and heroin.

Here, the officers' testimonies regarding Simba, along with Officer Tate's testimony regarding the conflicting stories between the two men and their nervousness, was sufficient to support the trial court's denial of the motion to suppress.Dawson v. State, 238 Ga.App. 263, 265(1), 518 S.E.2d 477 (1999). See id.

Here, the officers' testimonies regarding Simba, along with Officer Tate's testimony regarding the conflicting stories between the two men and their nervousness, was sufficient to support the trial court's denial of the motion to suppress. Dawson v. State, 238 Ga. App. 263, 265 (1) (518 SE2d 477) (1999). See id.

Second, Newton is mistaken in focusing solely on the odor of ether as providing the basis for a finding of probable cause in this case. See Dawson v. State, 238 Ga.App. 263, 265(1), 518 S.E.2d 477 (1999) (“Probable cause need not be defined in relation to any one particular element, but may exist because of the totality of circumstances.”) (citation and punctuation omitted).

Whether probable cause has been established will then be resolved by the trial court. Id. at 336 (citations omitted) (following Dawson v. State, 238 Ga.App. 263, 518 S.E.2d 477 (1999)). We certified direct conflict with Matheson.

The affidavit in support of the warrant recites the positive alert by Matson's canine, as well as the marijuana growing operation in the residence from which the vehicles drove away. Based on the totality of the circumstances, the affidavit provided the magistrate with a substantial basis for concluding that probable cause existed to believe that contraband would be found in the vehicles.Dawson v. State, 238 Ga. App. 263, 266-267 (1) ( 518 SE2d 477) (1999); Milan v. State, 228 Ga. App. 310, 311 ( 491 SE2d 401) (1997); Roundtree v. State, 213 Ga. App. 793, 794-795 ( 446 SE2d 204) (1994). See, e.g., Cole v. State, 279 Ga. App. 219, 223 (3) ( 630 SE2d 817) (2006) (affidavit and oral testimony provided magistrate with a substantial basis for finding probable cause that crimes occurred in defendant's vehicle).

Those courts have held that a certification that a dog has been trained is prima facie proof of the dog's reliability which then may be rebutted by the presentation of evidence regarding the dog's performance or training. See United States v. Hill, 195 F.3d 258, 273 (6th Cir. 1999);United States v. Diaz, 25 F.3d 392, 395 (6th Cir. 1994); Warren v. State, 561 S.E.2d 190, 194-95 (Ga.Ct.App. 2002); Dawson v. State, 518 S.E.2d 477, 481 (Ga.Ct.App. 1999). "Although the dog's `credibility' may be undermined by evidence of its lack of training or past unreliability, the ultimate determination as to whether the dog is sufficiently reliable to support a determination of probable cause is for the trial court as the trier of fact."

[Cit.] Dawson v. State, 238 Ga. App. 263, 267 (1) ( 518 S.E.2d 477) (1999). The officer who handled the drug detection dog testified to his training and the dog's training and certification by the Villa Rica Police Department and three state and national testing bodies.