probable cause and a considerably lower threshold than preponderance of the evidence); Gates, 462 U.S. at 244 n. 13, 103 S.Ct. 2317. Assuming that the dog is reliable, a dog sniff resulting in an alert on a container, car, or other item, standing alone, gives an officer probable cause to believe that there are drugs present. United States v. Sundby, 186 F.3d 873, 875-76 (8th Cir.1999). In finding sufficient the affidavit at issue in Sundby, we declared that “[in order to establish the dog’s reliability,] the affidavit need only state the dog has been trained and certified to detect drugs.... An affidavit need not give a detailed account of the dog’s track record or education.” Id. at 876 (citations omitted). Such statements only establish the affidavit’s facial validity, however. Id. (<HOLDING>). Because Baron’s performance record raises
holding a defendant is not entitled to a franks hearing without making a substantial preliminary showing that defect in the affidavit is material holding that each plaintiff is liable for fees if he would have been entitled to his fees if he had prevailed holding that the defendant had consented where he allowed the police officers into his apartment building and allowed the officers to follow him into his apartment without impediment or objection to the entry of the police holding that the defendant would have been entitled to a franks hearing had he shown that officers withheld negative information casting into doubt the dogs reliability holding that a defendant deprived of an opportunity to impeach an eyewitness by the governments failure to disclose documents that cast serious doubt on significant portions of her testimony was not entitled to relief because he had not shown that there is a reasonable probability that his conviction or death sentence would have been different had these materials been disclosed