It's always something. I had no idea that SCOTUS thought dogs were invincible. They've been reading too many comic books or something.
In Caballes v. Illinois, the 2005 Supreme Court decision that upheld the use of drug-sniffing canines during routine traffic stops, dissenting Justice David Souter noted that "the infallible dog...is a creature of legal fiction." Since false "alerts" seem to be fairly common, Souter warned, it's not safe to assume that signals from police dogs reliably indicate the presence of illegal substances, a premise underlying the Court's conclusion that a dog sniff does not count as a "search" for Fourth Amendment purposes. More...
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