By the numbers, the total of ten law enforcement K-9 heatstroke deaths that occurred in 2025 fits right into the historical pattern — more than 2024, but less than 2023, and the same, on average, with the decade prior.

Still, there was a positive development: K-9 heatstroke deaths were more widely and forthrightly acknowledged by law enforcement agencies. This trend of quickly informing the public, and taking more explicit responsibility for these tragedies — most of them avoidable — is a step forward in actively addressing the problem.

2025 K-9 Heatstroke Deaths

As reported in public media

Kai4/23/25Bristol TN PDTraining

Scout5/27/25Suffolk VA PDTracking

Baxter5/28/25Maine DPSIn-vehicle

Henk6/21/25Helen GA PDTraining

Ender6/25/25Dorchester Cty. MD SheriffIn-vehicle

Sam7/8/25Lexington Cty. SC SheriffTraining

Georgia7/13/25Dade Cty. GA SheriffIn-vehicle

Karma8/8/25Isanti Cty. MN SheriffTracking

Archer9/4/25Hawai'i Cty. HI PDIn-vehicle

Cooper9/5/25Muskingum Cty. OH SheriffIn-vehicle

This year, two K-9s died while deployed in tracking, a primary duty of K-9 teams, with recognized risk. The other eight deaths were unrelated to law enforcement action. Three occurred during or soon after organized training events. Five K-9s perished while confined in a vehicle.

Whether deployed at their most instinctual tasks, exercising in-step with their beloved Handler, or secured per protocol inside their specially-equipped duty vehicle — that is to say, practically anywhere in the course of their typical daily activities — healthy K-9's are at risk of suddenly incurring heatstroke and dying. Just as ubiquitously true is that, no one is more shocked and heartbroken by a K-9's heatstroke death than their Handler.

A Hopeful Trend

By the numbers, 2025 K-9 heatstroke deaths and their causes persisted in line with the long-term trend. But important cultural progress was demonstrated by departments' public acknowledgement of most of this year's tragedies. In general the reports were met by immediate social media response that was broadly angry, but also to some extent, sympathetic. Most reports triggered a cascade of external and internal challenges.

Each death was investigated internally, and in some cases, externally. Several Handlers were charged and/or fired outright. Others were disciplined. Probably none will be assigned to police K-9 duty ever again.

The departments took their lumps — public outrage, internal penitence, the loss of the canine's unique policing skills, a disgraced officer, disrepute among K-9 unit funding and support institutions, etc.

Some departments undertook internal review of the policy and protocol failures that may have contributed to the tragedy. One department made their internal findings and corrections public, by declaring policy changes where gaps had been found deficient.

Accepting tough medicine is an important cultural change. Not long ago, most unnecessary K-9 deaths were kept quiet, and responsibility obscured. This tendency persists: one department made a concerted effort to obfuscate a K-9's in-vehicle death. While the officers involved eluded statutory consequence, the department finds itself months later still under a spotlight and still in civil jeopardy, while their oversight governance structure is embarrassed by their inability to implement meaningful accountability.

Acceptance is the First Step

Ultimately, 2025 was another bad year for K-9 heatstroke. But wider acknowledgement of unnecessary K-9 deaths by departments, even in the face of severe consequences, is becoming a strong impetus to finally start acting effectively against heatstroke risk in 2026.

K-9Cooler's mission to AVOID, ALLEVIATE, and PREVENT heat injury to working dogs has inspired development of active-principle products that are effective against heat injury. Visit our store to learn how the K-9 Heatstroke Emergency Field Kit can multiply your K-9's chance of surviving a serious heat injury episode, and save your department from the disgrace of an unnecessary K-9 death.

*Joshua Davidson is the Founder of K-9Cooler, which makes products to AVOID, ALLEVIATE, and PREVENT heat injury to working dogs, including the K-9 Heatstroke Emergency Field Kit.*

‍

Scope of a Search When Executing a Search Warrant

USA v. Evans, (3d Cir. 2026) May 19th 2026

In United States v. Evans, officers obtained a warrant to search a New Jersey hotel room for evidence connecting its occupant to illegal firearms. During the search, a detective noticed a piece of broken ceiling tile sitting on the bed. Standing on the bed, he pressed on the damaged tile, causing a loaded pistol magazine to fall from the ceiling. Searching the area above the drop ceiling, officers recovered duffel bags containing drugs, cash, and other incriminating evidence.

Evans argued the search exceeded the warrant’s scope. The 3rd Circuit disagreed, holding the ceiling space was a reasonable place to search for the items listed in the warrant. The damaged ceiling, the fallen magazine, and Evans’ opportunity to access the area all supported the detective’s decision to search the ceiling cavity.

A search warrant authorizes officers to look anywhere the listed evidence could reasonably be hidden. As the U.S. Supreme Court explained in United States v. Ross (456 U.S. 798, 824 (1982)), the scope of a lawful search is defined by “the object of the search and the places in which there is probable cause to believe that it may be found.”

The principle is straightforward. A warrant for drugs, firearms, ammunition, cash, or documents may justify searching drawers, backpacks, crawlspaces … and the space above a drop ceiling. A warrant for a stolen refrigerator likely does not.

That’s precisely why the search in Evans was upheld. Firearm accessories and identifying evidence could reasonably have been hidden above the ceiling tiles.

‍

As the creator of PACKTRACK and an expert in the field I’m commonly asked about extending our K9 record keeping system to compute an accuracy percentage statistic during K9 detection training.

The requested method of calculating this statistic is simple. If the dog finds or “hits” the target odor then it’s marked as correct. When the dog doesn’t find or “misses” the target odor then it’s marked as incorrect. If the dog indicates that a target odor is present when it isn’t (sometimes referred to as a “false alert”) then it’s also marked as incorrect. The statistic is calculated based on the percentage of correct responses.

The request for this feature may come from a misunderstanding of the 2013 Supreme Court case of Florida v Harris or be based on advice received from a trainer. The US Supreme Court ruling in this case explicitly rejected an earlier Florida court ruling that favored “rigid rules” in favor of a “Totality of Circumstances” approach. The key problem with using an accuracy percentage calculation in deployments is that it’s impossible to accurately say whether the dog was incorrect. The Supreme Court ruling went even further by stating that probable cause cannot be and has never been based on a “bright-line test” such as a statistical calculation. Probable cause is based on a “totality of the circumstances” analysis. Based on this decision, the idea of using an accuracy statistic for training would not be beneficial in court.

Another problem with this idea is it presumes that the outcome of a training exercise provides confirmation that the training was done correctly. It seems logical to assume that hits are correct responses while misses and false alerts are incorrect responses. However, this simplification reads more into the data than is captured. The idea that we can equate locating a target odor (a hit) to a determination of whether the training was done correctly is absurd. It’s like presuming that since no tangible substance was found after a K9 indication during a deployment that this indication must have been a false alert or somehow incorrect.

Behavior modification in drug detection training is mainly done with positive reinforcement at the appropriate time. Handlers can inadvertently train canines to respond to a “cue”, a behavior, sound, or action that the canine learns as a signal to respond in a positive way that a target odor is present. The canine learns this behavior over a series of exercises where the cue (an action taken by the handler) was done and the canine was rewarded in a positive manner. This cueing is consistently reinforced by the handler during training exercises and may cause what some call a “false alert”. While this “false alert” will be correctly marked as an incorrect response by the dog, it is actually a red flag that there is a training issue. The real incorrect training exercises are those prior to the “false alert”, when the handler performed the cue where target odor was concealed, and the canine was rewarded. During those exercises the canine was taught the cue. These exercises would be marked as “hits” with the presumption that the exercises were conducted correctly when in fact they were not.

An accuracy statistic requires that we read too much into the outcome of an exercise. There is no way to provide this statistic and we shouldn’t try. Training time should be focused on finding and correcting the problems that we, as handlers and trainers, may have caused. Training is the time to push teams to their limits and beyond. Handlers should come to training feeling free to make and learn from their mistakes so they can prevent and correct them in future training. Exercises should condition handlers to perform proper technique while increasing their knowledge and perfecting the skill of dog handling.

In using the proposed statistic handlers are forced to only work to the limit of correct performance. They will only do exercises that they know they can complete properly in order to maximize their accuracy percentage. Who would want to push themselves to the point of error if a statistic, which provides no explanation, will be used to gauge their reliability?

My advice is to be careful if you quantify your hits, misses and false alerts as a percentage of accuracy. You are keeping records that can negatively impact the quality of your training and provide a false sense of proper training. And, if you’re challenged in court, it’s unlikely that this statistic will do much to help you win a reliability argument. There are better ways to train and document your records and we will talk about this in future posts. Stay tuned.

‍