ABSTRACT
Under consideration in the federal government’s Ninth Circuit Court of Appeals in United States v. $30,060 in U.S. Currency,1 in January of 1994, was the future of narcotics detection canine alerts as an investigative tool of law enforcement in instances where a large sum of currency is encountered in transit and pursuit of the forfeiture process is undertaken. The foundation for the circuit court’s ruling would be based upon its 1988 ruling in United States v. Dickerson.2 Dickerson had held that with cases of the interdiction of large sums of currency, the transition from mere suspicion to probable cause requires demonstration that the money was involved in drug trafficking.
