You'll remember that a while back I published a brief I wrote for a trial court in support of a motion to dismiss under the 4th Amendment. The prosecutor lost and filed a petition for appeal to the Virginia Court of Appeals. In it he changed his argument from "the search of the truck was valid and therefore the search of Ms. Smith was valid" to "the misread of the dog's indication that Ms. Smith had drugs did not remove the probable cause to search her and therefore the search of Ms. Smith was valid."
Here's my Brief in Opposition to Petition for Appeal.
This was written in a day and therefore it's rough but I think that 90% of it is spot on. The other 10% I wanted more time to research and polish but I didn't have it (you'll find out the reason in next Week in the Life).