he received a 40-hour refresher seminar by another police department in dothan, alabama. and he was subjected to continuous weekly training, in which part of that training consisted of taking him out, walking him by some vehicles that contained cars, some vehicles that didn't. and the testimony of officer wheetley was that aldo's performance was really good. and what he meant by that was that if there were eight cars with drugs. >> then why did -- then why didn't they get the dog recertified? by the time of the search, the certification had expired 16 months. >> it was a lapse, your honor. the dog subsequently was recertified. our position is that the fourth amendment doesn't impose an annual certification requirement. some states have it, some states don't. i think, more important in this case was the fact that the dog was continuously trained, continuously evaluated and trained. >> well, what do you -- what do you have to show to establish that the dog was well trained. >> well, your honor, i think the most important thing is successful completion of proficiency testing