Suggested Questions to Ask Expert in Dog Tracking Examination:
[These questions assume the dog was a bloodhound. Modify the questions if the dog is of a different breed, and ensure that the witness testifies about the breed's reputation for "acuteness of scent and power of discrimination."]
- What breed of dog did you use in your investigation on (give date)?
- Is the bloodhound pedigreed? That is, is the dog known to be of pure blood or descended from pure bloodhounds? [If not, what is the dog’s predominant breed make-up?]
- How old was the dog and what was its health?
- What is the particular characteristic of the bloodhound breed of dog in terms of ability to detect and follow a scent?
- Is the bloodhound able to discriminate between different human scents?
- How old of a scent is the bloodhound able to pick up?
- Had this bloodhound been trained to track the human scent? [Length of training, where trained, qualifications of trainer, how trained?]
- Had the dog’s reliability been tested by previous experiences tracking human tracks in real pursuits?
- How many times was the bloodhound successful in tracking on those occasions?
- Was the dog under your control on (give date)?
- Had you previously used this dog in conducting an investigation? What was the result?
- How do you put a bloodhound on a particular human track?
- How did you put the bloodhound on the suspect’s track in this investigation?
- [If dog was exposed to property or clothing of suspect, ask:]
a. Where did you get the (article belonging to the trailed person)?
b. What led you to believe that it belonged to (the trailed person/defendant)?
c. Where were you when you showed the (article) to the bloodhound?
- [If dog was taken to a location where the trailed person had recently been, ask:]
a. What led you to believe that the suspect had been at this location?
b. How long before you took the bloodhound there had the suspect been at the location?
- What did the bloodhound do?
[Ask for description of trail followed, location, time, whether human footprints were seen, conduct of dog while tracking.]
- Did the dog’s trail lead you to a person?
[Ask for description of conduct of dog at end of the trail—whether dog bayed or identified a person.]
- Do you see that person in the courtroom today?
[Have witness identify the defendant.]
- Where was the defendant when the dog led you to the defendant?