U.S. v. Lawrence

In prosecution on drug distribution charge, Dist. Ct. did not err in denying defendant’s motion to preclude evidence that trained dog alerted authorities to presence of drug residue on currency found in defendant’s home. While defendant argued that dog alert evidence was meaningless since large percentage of U.S. currency already had presence of illegal drugs, there is no per se rule that dog alerts on currency are unreliable, since recent empirical and scientific evidence indicate that dog will alert only to large amount of illicit drugs on currency. Prosecutor, though, erred when presenting evidence about statement defendant made to officer, where prosecutor had failed to disclose said statement to defendant prior to trial. However, said error was harmless where Dist. Ct. gave timely curative instruction to jury.