whether a right is clearly established, we may rely upon cases of controlling authority in the jurisdiction in question, or a ‘consensus of cases of persuasive authority such that a reasonable officer could not have believed that his actions were lawful.’ ” Rogers v. Pendleton, 249 F.3d 279, 287 (4th Cir.2001) (quoting Wilson v. Layne, 526 U.S. 603, 617, 119 S.Ct. 1692, 143 L.Ed.2d 818 (1999)). While there is no Supreme Court or Fourth Circuit case directly on point, each of the three circuits to have considered whether an individual has a constitutional right to be free from the unreasonable destruction of his or her dog has found that right to be clearly established. See Brown v. Muhlenberg Township, 269 F.3d 205, 211 (3rd Cir.2001); Lesher v. Reed, 12 F.3d 148, 151 (8th Cir.1994) (<HOLDING>); Fuller v. Vines (Fuller I), 36 F.3d 65, 68
holding that a search of the plaintiffs residence was reasonable within the meaning of the fourth amendment where an informant provided information to the beloit police department that there were or might be guns in the plaintiffs apartment holding that a dog sniff outside the defendants door in his apartment building was not a search within the meaning of the fourth amendment so long as the police were lawfully present in the hallway when the search occurred holding that a police department is not a person within the meaning of section 1983 holding that a dog that was destroyed by the police department was obviously  seized within the meaning of the fourth amendment holding that where an individual voluntarily goes to the police station to discuss the commission of a crime that person has not been seized within the meaning of the fourth amendment