drug dog searches and asset seizures and forfeitures

Discussion of Searches and Currency ForfeitureBased on Drug Dog Alerts 1

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Discussion of Searches and Currency ForfeitureBased on Drug Dog Alerts

Police seize money from thousands of people each year because a dog with a badge sniffs, barksor paws to show that bills are tainted with drugs.

But some scientists say the test the police rely on is no test at all because drugs contaminatevirtually all the currency in America.

Over a seven-year period, Dr. Jay Poupko and his colleagues at Toxicology Consultants Inc. inMiami have repeatedly tested currency in Austin, Dallas, Los Angeles, Memphis, Miami,Milwaukee, New York City, Pittsburgh, Seattle and Syracuse. He also tested American bills inLondon.

"An average of 96 percent of all the bills we analyzed from the 11 cities tested positive forcocaine. I don't think any rational thinking person can dispute that almost all the currency in thiscountry is tainted with drugs," Poupko says.

Scientists at National Medical Services, in Willow Grove, Pa., who tested money from banks andother legal sources more than a dozen times, consistently found cocaine on more than 80 percentof the bills.

"Cocaine is very adhesive and easily transferable," says Vincent Cordova, director ofcriminalistics for the private lab. "A police officer, pharmacist, toxicologist or anyone else whohandles cocaine, including drug traffickers, can shake hands with someone, who eventuallytouches money, and the contamination process begins."

Cordova and other scientists use gas chromatography and mass spectroscopy, precise alcoholwashes and a dozen other sophisticated techniques to identify the presence of narcotics down tothe nanogram level one billionth of a gram. That measure, which is far less than a pin point, isthe same level a dog can detect with a sniff.

What a drug dog cannot do, which the scientists can, is quantify the amount of drugs on the bills.


Half of the money Cordova examined had levels of cocaine at or above 9 nanograms. This levelmeans the bills were either near a source of cocaine or were handled by someone who touchedthe drug, he says.

Another 30 percent of the bills he examined show levels below 9 nanograms, which indicates"the bills were probably in a cash drawer, wallet or some place where they came in contact withmoney previously contaminated."

The lab's research found $20 bills are most highly contaminated, with $10 and $5 bills next. The$1, $50 and $100 bill usually have the lowest cocaine levels.

Cordova urges restraint in linking possession of contaminated money to a criminal act."Police aid prosecutors have got to use caution in how far they go. The presence of cocaine onbills cannot be used as valid proof that the holder of the money, or the bills themselves, have everbeen in direct contact with drugs," says Cordova, who spent 11 years directing the PhiladelphiaPolice crime laboratory.

Nevertheless, more and more drug dogs are being put to work.

Some agencies, like the U.S. Customs Service, are using passive dogs that don't rip into an itemor person - when the dogs find something during a search. These dogs just sit and wag their tails.German shepherds with names like Killer and Rambo are being replaced by Labradors namedBruce or Memphis' "Chocolate Mousse."

Marijuana presents its own problems for dogs since its very pungent smell is long-lasting.Trainers have testified that drug dogs can react to clothing, containers or cars months aftermarijuana has been removed.

A 1989 case in Richmond, Va., addressed the issue of how reliable dogs are in marijuanasearches.

Jack Adams, a special agent with the Virginia State Police, supervised training of drug dogs forthe state.

He said the odor from a single suitcase filled with marijuana and placed with 100 other bags in aclosed Amtrak baggage car in Miami could permeate all the other bags in the car by the time thetrain reached Richmond.

And what happens to the mountain of "drug-contaminated" dollars the government seizes eachyear? The bills aren't burned, cleaned, or stored in a well-guarded warehouse.


Twenty-one seizing agencies questioned all said the tainted money was deposited in a local bank- which means it's back in circulation.

Case Law – Drug Dog Searches

In United States v. Place, a 1983 Supreme Court decision, the Court ruled that exposure ofluggage located in a public place "did not constitute a search within the meaning of the FourthAmendment."

In Place, the defendant aroused the suspicions of DEA agents in the Miami International Airport.They conducted a brief investigation and examined Place's airline ticket and drivers license.Although Place consented to a search of his luggage, the agents declined to search because theyfeared that he would miss his plane and the DEA would be liable for the cost of the ticket. Theagents telephoned other DEA agents at New York's LaGuardia Airport to pass on their suspicionsabout Place. Once Place arrived in New York, he was met by DEA agents who again askedconsent to search his luggage. This time, however, Place refused to consent. The agents thendetained Place's luggage and took the luggage to the Kennedy Airport where a trained drugdetection dog sniffed the luggage and gave an alert.

"Alert" is the term which describes the dog's behavior when the dog detects the odor of drugswhich it is trained to identify. Based on the dog's alert, the agents continued to detain theluggage. Place had not been detained.

A federal judge issued a search warrant for Place's luggage. A large quantity of drugs was found,and Place was later arrested.

Ultimately, the Supreme court reversed Place's conviction, but not on the basis of the search. TheCourt ruled that the pre-sniff seizure of the luggage was too long (ninety minutes) to bereasonable. The Court was also troubled by the fact that the agents had not told Place where hisluggage was being taken, how long it would be detained, and how he would be able to retrieve it.Nonetheless, the Court took great pains to clarify that the dog's alert created sufficient reason forfurther detention of the luggage.

Once the dog alerted on the luggage, there was probable cause to search the luggage. The FourthAmendment requires both probable cause and a search warrant -- or an exception to the warrantclause -- to search. None of the traditional warrant requirement exceptions, such as searchincident to arrest, plain view, automobile, exigency, or stop and frisk, applied in the Placecircumstances. Therefore the agents had to obtain the search warrant.


The Court also ruled that the dog's sniff of the luggage did not amount to a search. Canine sniffsare not intrusive. Place was not required to open his luggage and expose his personal items topublic view. The dog's sniff would only reveal the presence of contraband (presumably the dogwould not have alerted on even a full case of dog biscuits). The Court has also ruled that onecannot have a reasonable expectation of privacy in contraband, in United Stated v. Jacobson. ThePlace Court ruled:

A canine sniff by a well-trained narcotics detection dog does not require opening theluggage. It does not expose noncontraband items that otherwise would remain hiddenfrom public view, as does, for example, an officer's rummaging through the contents ofthe luggage. Thus, the manner in which information is obtained through this investigativetechnique is much less intrusive than a typical search. Moreover, the sniff discloses onlythe presence or absence of narcotics, a contraband item. Thus, despite the fact that thesniff tells the authorities something about the contents of the luggage, the information islimited. That limited disclosure also ensures that the owner of the property is notsubjected to the embarrassment and inconvenience entailed in less discriminate and moreintrusive investigative methods. . . . Therefore, we conclude that . . . exposure of Place'sluggage, which was located in a public place, to a trained canine -- did not constitute asearch within the meaning of the Fourth Amendment.

Lower federal courts and many state courts have relied on United States v. Place to establish afirm rule that a positive alert by a trained drug detection dog creates probable cause to search andprobable cause to arrest.

The Tenth Circuit Court of Appeals has stated: "a dog alert is at least as reliable as many othersources of probable cause and is certainly reliable enough to create a fair probability that there iscontraband. We therefore have held in several cases that a dog alert without more gave probablecause for searches and seizures." United States v. Ludwig. Some courts have requiredindependent reasonable suspicion of drug activity, in addition to the alert, to establish probablecause. In another decision the Tenth Circuit court ruled that "a drug sniffing dog's detection ofcontraband . . . establishes probable cause, enough for the arrest, more than enough for the stop."United States v. Williams.

In an opinion by Chief Judge Edmondson, the Eleventh Circuit reversed a $242,484 forfeitureorder and instructed the trial court to enter a judgment for the claimant. The appellate court heldthat "the government’s case falls short of the probable cause line." Since the government failed toestablish an adequate link between the money and any illegal drugs alleged in the forfeiturecomplaint, the claimant was not required to prove she had a legitimate source of the cash seizedfrom her by the DEA. [United States v. $242,484, 11th Cir. (2003) No, 01-16485, DC DocketNo. 99-01259 CV-DMM]


Steven L. Kessler, former head of the New York state forfeiture office who now representspeople challenging government claims, commented on the appellate court reversal of theforfeiture order: "Enough smoke in the past has been the basis for forfeitures, and I think the 11thCircuit at least is saying, ‘We need a little bit of a fire. The smoke itself won’t do it.’"

The January 23 (2003) decision ordered return of the cash seized in 1998 from Deborah Stanford,owner of Mike’s Import and Export in Florida. Ms. Stanford was en route to Miami in December1998 when airport security officers in New York questioned her about her packages, and shereplied they contained money. She caught her flight as security notified the U.S. DrugEnforcement Agency.

Six Florida DEA agents waited at the airport gate for Stanford’s flight to arrive. At the request oftwo of the agents, Stanford gave them her ticket and identification. They verified her name andreturned the items. The agents asked her if she was carrying drugs or money, and she said shewas carrying about $200,000 cash in her backpack. Stanford gave one of the agents permission tolook into her backpack. The agent saw a "Christmas bag type package," into which he poked ahole revealing bundles of cash.

The agents asked Stanford to accompany them to the DEA office. She agreed, and upon furtherquestioning told them she was in New York for a court case. She later said she was there to pickup money. According to court records she could not, or would not, reveal where she stayed inNew York nor who gave her the cash other than to say that she received a call from her brother,who told her to meet some people and pick up money for Mike’s Import and Export. She did notproduce any documentation connecting the currency to Mike’s.

The agents brought in "Rambo," a drug-sniffing dog, and placed the backpack in a hallway withother packages of similar weight and shape. The dog alerted on the backpack with the cash andagents took the money in exchange for a receipt for the seized currency. No criminal chargeswere filed, but federal prosecutors sought civil forfeiture of the money, claiming it was linked todrug crimes.

The appellate court stressed that because the forfeiture was based on 21 USC 881(a)(6), the drugproceeds forfeiture provision, "not just any criminal activity will support the forfeiture: the formof the criminal wrongdoing must involve ‘the exchange of a controlled substance.’"

The district court had relied on a number of circumstances to establish its finding of probablecause: (1) "the quantity of cash and its physical condition;" (2) "the route and circumstancessurrounding Ms. Stanford’s travel;" (3) "Ms. Stanford’s lack of knowledge concerning thecircumstances surrounding her trip to New York and the receipt of this money, including herinability to identify from whom she received it;" (4) "that Ms. Stanford twice was a ‘no show’ forher scheduled departure from New York to Miami;" and (5) "a narcotics dog alerted on the cash."


The appellate court found Stanford’s inability or unwillingness to state where she stayed in NewYork or identify the persons who gave her the cash to be "troubling," stating that such "evasiveanswers are suspicious and add to the Government’s case for probable cause." However, theEleventh Circuit held that:

under the law, a claimant is under no duty to show that "the property derived from alegitimate source" until the Government first can establish probable cause of a substantialconnection to a controlled-substance transaction.

Allowing the Government to base probable cause on the failure to identify a legitimate source ofthe currency unlawfully reverses this burden. Stanford’s failure to identify the people who gaveher the currency and to provide receipts is relevant to her ability to show a legitimate source orinnocent ownership, but she is not required to make this showing until the Governmentestablishes probable cause.

The appellate justices also agreed with the district court that "the narcotics-detection dog’s alertto the currency is also worth noting, although perhaps worth little else" in the totality ofcircumstances of the case, stating: "The probative value of dog alerts to the smell of narcotics oncurrency has been called into question of late. Testimony indicated that as much as 80% ofmoney in circulation may carry residue of narcotics."

The court noted the irony that on the day after seizing the cash the DEA exchanged this drug-tainted currency for a cashier’s check at a local bank, where the currency was possibly placedback into circulation for innocent people to possess. The court concluded "the dog alert, at best,tells us that this currency (like most circulated currency) may have been exposed, at some point,to narcotics."

The Eleventh Circuit reversed the forfeiture order, concluding:

Given the weakness of the elements presented, and the complete lack of evidenceconnecting the seized money directly to illegal narcotics, the Government’s case fallsshort of the probable-cause line. This citizen can keep her property.

Drug-tainted money and dog alerts

United States v. Six Hundred Thirty-Nine Thousand Five Hundred and Fifty-EightDollars ($639,558) In United States Currency, 955 F.2d, 1992, Page 714, footnote 2, "Dr.James Woodford, testified that 90 percent of all cash in the united States containssufficient quantities of cocaine to alert a trained dog."


United States v. Carr, 25 F.3d 1194 (3rd Cir, 1994). Page 1215, footnote #6: "Dr. JamesWoodford, testified that 90 percent of all cash in the United States contains sufficientquantities of cocaine to alert a trained dog."

United States v. U.S. Currency, $30,060.00, 39 F.3d, 1039 (9th Cir. 1994). Pate 1043,"(referring to testimony of Dr. James Woodford that ninety percent of all cash in theUnited States contains sufficient quantities of cocaine to alert a narcotics detection dog);"

United States v. $5,000 in U.S. Currency and $9,750 in U.S. Currency, 40 F.3d 846 (6th

Cir. 1994). Page 849, "Dr. James Woodford testified that 90 percent of all cash in theUnited States contains sufficient quantities of cocaine to alert a trained dog."

United States v. Saccoccia, 58 F.3d 754 (1st Cir. 1995). 77, footnote #18 The courtpermitted Dr. Woodford to, "describe the report’s conclusions and to indicate that he hadrelied on those findings."

United States v. Barnhardt, 1993 WL 127094, *24 (M.D.Tenn.). Page 22, "(stating thatDr. Woodford testified that, as a result, bills may contain as little as a millionth of a gramof cocaine, but that is many times more cocaine than is needed for a dog to alert."

Endnotes:

United States v. $242,484, 11th Cir. (2003) No, 01-16485, DC Docket No. 99-01259 CV-DMM$121,100.00, 999 F.2d at 1505United States v. $506,231 in U.S. Currency, 125 F.3d 442, 453 (7th Cir. 1997); United States v.$53,082.00 in U.S. Currency, 985 F.2d 245, 250 n.5 (6th Cir. 1993).


DEA Intelligence BriefSupreme Court Confirms That a Dog Sniff of a Car During a Traffic Stop is not a Fourth

Amendment Search

Jayme Walker HolcombeAssociate Chief Counsel Legal Instruction Section

U.S. Drug Enforcement Administration Quantico, Virginia

[From The Police Chief 2005;72(3):8 Unclassified, Reprinted with Permission.]

A dog sniff of an inanimate object that law enforcement officers have lawfully seized isnot a search within the meaning of the Fourth Amendment. The U.S. Supreme Courtonce again confirmed this principle in the Court’s recent decision of Illinois v. Caballes.[1] In Caballes the Court addressed the use of a narcotics-detection dog to sniff a carduring the course of a traffic stop. In a 6-2 vote overturning the judgment of the IllinoisSupreme Court, the U.S. Supreme Court stated that a “dog sniff conducted during aconcededly lawful traffic stop that reveals no information other than the location of asubstance that no individual has any right to possess does not violate the FourthAmendment.” [2]

The Traffic Stop

In Caballes an Illinois state trooper stopped the defendant for speeding. After thetrooper informed the dispatcher that he was making the stop, another trooper whoheard the radio transmission immediately went to the location of the stop with hisnarcotics-detection dog. The trooper who made the traffic stop had not requested theassistance of the canine unit.

When the canine unit arrived at the scene, the defendant's car was parked on theshoulder of the highway. The defendant was sitting in the car of the trooper who hadpulled him over for the traffic violation and that trooper was still writing him a warningticket. The second trooper walked his dog around the defendant's car. The dog quicklyalerted to the defendant’s trunk. The troopers searched the trunk and found marijuanainside. The U.S. Supreme Court specifically noted that the “entire incident lasted lessthan 10 minutes.” [3]

The trial court denied the defendant’s motion to suppress and found the defendantguilty after a bench trial. The trial court sentenced the defendant to a $256,136 fine and12 years’ imprisonment. The appellate court affirmed. The Illinois Supreme Court


reversed the judgments of the lower courts and concluded that the use of the dog in thecase unjustifiably expanded the scope of the traffic stop without the requisite level ofsuspicion to suggest drug activity.

The Dog Sniff

In Caballes the U.S. Supreme Court agreed to review the case [4] to address thenarrow question of “whether the Fourth Amendment requires reasonable, articulablesuspicion to justify using a drug-detection dog to sniff a vehicle during a legitimate trafficstop.” [5] Because the Court proceeded under the assumption that the trooper whowalked the dog around the car had no information about the defendant other than thathe had been stopped for speeding, the Court omitted any reference to any facts aboutthe defendant that may have been suspicious.

The Court found that the trooper's stop of the defendant for speeding was a concededlylawful seizure based on probable cause. The Court stated, however, that it “isnevertheless clear that a seizure that is lawful at its inception can violate the FourthAmendment if its manner of execution unreasonably infringes interests protected by theConstitution.” [6] The Court explained that a traffic stop could become unlawful if theseizure is justified only by the interest in issuing a warning ticket and it “is prolongedbeyond the time reasonably required to complete that mission.” [7]

The U.S. Supreme Court took issue with the Illinois Supreme Court's position that thecanine sniff outside of the defendant's car made the initially lawful stop for the speedingviolation an unlawful seizure. The Illinois Supreme Court had expressed the view thatthe use of the dog without any reasonable suspicion that the defendant's car containednarcotics converted the police-citizen encounter from the traffic stop into a druginvestigation. In considering this issue, the U.S. Supreme Court stated:

“In our view, conducting a dog sniff would not change the character of a trafficstop that is lawful at its inception and otherwise executed in a reasonablemanner, unless the dog sniff itself infringed respondent's constitutionallyprotected interest in privacy. Our cases hold that it did not.” [8]

The U.S. Supreme Court cited a number of its prior decisions in reaching theconclusion that the use of the dog in Caballes did not violate the Fourth Amendment.For example, the court cited the 1984 case of United States v. Jacobsen. [9] TheJacobsen case involved a Drug Enforcement Administration (DEA) agent who opened adamaged package containing four plastic bags of white powder concealed in a tubeinitially opened by employees of an overnight delivery company. The agent removed atrace amount of the powder from one of the bags, conducted a field test, anddetermined the substance to be cocaine. The Court concluded: “A chemical test thatmerely discloses whether or not a particular substance is cocaine does not compromise


any legitimate interest in privacy.” [10] Citing to Jacobsen, the Court in Caballes stated:“Official conduct that does not ‘compromise any legitimate interest in privacy’ is not asearch subject to the Fourth Amendment.” [11]

The Court also mentioned United States v. Place [12] and Indianapolis v. Edmond [13],two prior U.S. Supreme Court cases that addressed narcotics-detection dog sniffs. The1983 case United States v. Place involved the exposure of a temporarily detained pieceof luggage to a narcotics-detection dog. In Place agents seized Place’s bag and, 90minutes later, submitted it to a canine sniff. The Court found the initial seizure ofPlace’s luggage legitimate based on a reasonable suspicion that it containedcontraband. However, the Court proceeded to find that the length of the detention of thebag, standing alone, constituted a Fourth Amendment violation in the absence ofprobable cause. After stating that a person has a privacy interest protected by theFourth Amendment in the contents of luggage, the Court concluded that the exposureof the luggage to a canine sniff did not constitute a search. The Court stated:

“A ‘canine sniff’ by a well-trained narcotics-detection dog, however, does notrequire opening the luggage. It does not expose noncontraband items thatotherwise would remain hidden from public view, as does, for example, anofficer's rummaging through the contents of the luggage. Thus, the manner inwhich the information is obtained through this investigative technique is muchless intrusive than a typical search. Moreover, the sniff discloses only thepresence or absence of narcotics, a contraband item. Thus, despite the fact thatthe sniff tells the authorities something about the contents of the luggage, theinformation obtained is limited. This limited disclosure also ensures that theowner of the property is not subjected to the embarrassment and inconvenienceentailed in less discriminate and more intrusive investigative methods.” [14]

In City of Indianapolis v. Edmond officers walked a narcotics-detection dog around carsstopped at a narcotics checkpoint established by police. Although the Court found thatthe checkpoints violated the Fourth Amendment, the Court stated the following withrespect to the canine sniffs:

“The fact that officers walk a narcotics-detection dog around the exterior of eachcar at the Indianapolis checkpoints does not transform the seizure into a search.Just as in Place, an exterior sniff of an automobile does not require entry into thecar and is not designed to disclose any information other than the presence orabsence of narcotics. Like the dog sniff in Place, a sniff by a dog that simplywalks around a car is ‘much less intrusive than a typical search.’” [15]

Reaffirming this principle in Caballes, the Court stated that it had previously treated anarcotics-detection dog sniff as unique “because it ‘discloses only the presence orabsence of narcotics, a contraband item.’” [16]


In Caballes the Court found it significant that the second trooper walked the dog aroundthe outside of the defendant's car while he was lawfully seized for speeding. The Courtstated: “Any intrusion on respondent's privacy expectations does not rise to the level ofa constitutionally cognizable infringement.” [17] This is consistent with the previouspositions taken by the Court in both Place and Edmond. The Court also stated thatthere was no evidence or findings in the record to support the defendant's argumentthat dog alert error rates call into question whether narcotics-detection canines onlyalert to contraband.

The Court ended its short opinion in Caballes with a discussion of its 2001decision inKyllo v. United States. [18] In Kyllo the court ruled that “the use of a thermal-imagingdevice to detect the growth of marijuana in a home constituted an unlawful search.” [19]The Kyllo Court had been concerned about using a device to detect lawful activitytaking place in a person's home. The Court distinguished the Caballes decision fromKyllo by specifically stating: “The legitimate expectation that information about perfectlylawful activity will remain private is categorically distinguishable from respondent’shopes or expectations concerning the nondetection of contraband in the trunk of hiscar.” [20]

Summary

The holding in Caballes is a narrow one, but the case provides important guidance forlaw enforcement. Following the logic of the Caballes majority, the Court confirmed thatthere is no legitimate privacy interest in contraband. Because a dog sniff by a well-trained narcotics-detection dog is likely to disclose only the presence or absence of acontraband item, that sniff is not a Fourth Amendment search when done during alawfully made and ongoing traffic stop. The Court has confirmed, once again, theprinciple that once the police lawfully seize an item, the use of a narcotics-detection dogto sniff the item without a search warrant or other applicable exception to the searchwarrant requirement does not transform the seizure into an unlawful search.

It also should be noted that the Court stated that an initially lawful seizure could betransformed into an unlawful seizure if “its manner of execution unreasonably infringesinterests protected by the Constitution.” [21] If a narcotics-detection dog sniff wereconducted during an unlawful detention, the Court implied that the use of the dog andany resulting discovery of contraband would be found to constitute the product of anunlawful seizure. [22] Because of the narrowness of the Court's decision in Caballes,officers should continue to consult with their legal advisors regarding the use ofnarcotics-detection dogs during traffic stops and in other investigative situations andcontexts. [23]


1. 125 S. Ct. 834, 2005 WL 123826 (U.S.). 2. Id. at 838, 2005 WL 123826 at *3. 3. Id. at 835, 2005 WL 123826 at *1.4. 541 U.S. 972 (2004). 5. 125 S. Ct. 834, 2005 WL 123826 (U.S.). 6. Id. at 835, 2005 WL 123826, at *1.7. Id. at 837, 2005 WL 123826, at *2. 8. Id. 9. 466 U.S. 109 (1984). 10. Id. at 123. 11. 125 S. Ct. 834, 2005 WL 123826 (U.S.). 12. 462 U.S. 696 (1983). 13. 531 U.S. 32 (2000). 14. 462 U.S. 696, 707 (1983). 15. 531 U.S. 32, 40 (2000). 16. 125 S. Ct. 834, 837, 2005 WL 123826 at *2 (U.S.). 17. Id. at 838, 2005 WL 123826, at *3. 18. 533 U.S. 27 (2001). 19. 125 S. Ct. 834, 838, 2005 WL 123826 at *3 (U.S.). 20. Id. 21. Id. at 837, 2005 WL 123826, at *2. 22. Id. 23. For additional information regarding these issues see: Jayme S. Walker "UsingDrug Detection Dogs - An Update," FBI Law Enforcement Bulletin, April 2001.

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[Notes: Selected references are a compilation of recent publications of presumedinterest to forensic chemists. Unless otherwise stated, all listed citations are publishedin English. Listed mailing address information (which is sometimes cryptic orincomplete) exactly duplicates that provided by the abstracting services. Patents arereported only by their Chemical Abstracts citation number.]

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Ni YN, Wang YR, Kokot S. Differential pulse stripping voltammetricdetermination of paracetamol and phenobarbital in pharmaceuticalsassisted by chemometrics. Analytical Letters 2004;37(15):3219. [Editor’sNotes: Presents the title study. Contact: Nanchang Univ, Dept Chem, Nanchang330047, Jiangxi, Peoples R China.]

Sanger M. Plant identification by DNA. Part II. Species identification ofmarijuana by DNA analysis. Forensic Botany 2004:159. [Editor’s Notes: Aminor overview and review. Contact: Appalachian H.I.D.T.A. Marijuana SignatureLaboratory, Frankfurt, KY (zip code not provided in the abstract).]


Swist M, Wilamowski J, Zuba D, Kochana J, Parczewski A. Determination ofsynthesis route of 1-(3,4-methylenedioxyphenyl)-2-propanone (MDP-2-P)based on impurity profiles of MDMA. Forensic Science International2005;149(2-3):181. [Editor’s Notes: Marker compounds were identified for theisosafrole and nitropropene routes to MDP2P. Contact: Department of AnalyticalChemistry, Faculty of Chemistry, Jagiellonian University, Ingardena 3, Krakow30-060, Pol.]

Xie Z-r. Determination of the morphine in complex background by tandemmass spectrometry. Zhipu Xuebao 2004;25(Suppl.):103. [Editor’s Notes:Presents the title study. This article is written in Chinese. Contact: ZhengzhouInstitute of Forensic Science, Zhengzhou 450003, Peop. Rep. China.]

Zheng C-s, Zheng H, Liu K-l, He Y, Hou Z-p. Analysis of lysergide tablets by gaschromatography - mass spectrometry. Zhipu Xuebao 2004;25(Suppl.):161.[Editor’s Notes: Uses liquid-liquid extraction and optimized GC/MS. This article iswritten in Chinese. Contact: Institute of Forensic Science of the Public SecurityMinistry of China, Beijing 100038, Peop. Rep. China.]

Additional References of Possible Interest:

Abrahamsson C, Johannsson J, Andersson-Engels S, Svanberg S, Folestad S.Time-resolved NIR spectroscopy for quantitative analysis of intactpharmaceutical tablets. Analytical Chemistry 2005;77(4):1055. [Editor’s Notes:The presented technique is claimed to be superior to standard NIR spectroscopyin that it can handle changes in the physical properties across the surface of asample. Contact: Department of Physics, Lund Institute of Technology, P.O. Box118, SE-221 00 Lund, Sweden.]

Bradbury J. Silence of the poppies: A new source of drug precursors. DrugDiscovery Today 2005;10(1):5. [Editor’s Notes: A brief overview of geneticmanipulation of opium poppies to generate preferred (non-morphine) alkaloidsas the primary bioproduct. Contact: No addressing information was provided.]

Bucheler R, Gleiter CH, Schwoerer P, Gaertner I. Use of nonprohibitedhallucinogenic plants: Increasing relevance for public health.Pharmacopsychiatry 2005;38(1):1. [Editor’s Notes: An overview and a casereport of the use of salvia divinorum. Includes 48 references. Contact: Abteilung


Klinische Pharmalologie, Universitatsklinikum Tubingen, Otfried Muller Strasse45, 72076 Tubingen, Germany.]

Deisingh AK. Pharmaceutical counterfeiting. Analyst 2005;130(3):271. [Editor’sNotes: An overview; includes detection methods to, and anti-counterfeitingmeasures. Contact: Caribbean Industrial Research Institute, University of theWest Indies, St. Augustine, Trinidad and Tobago.]

Esteve-Turillas FA. Validated, non-destructive, and environmentally friendlydetermination of cocaine in euro bank notes. Journal of Chromatography A2005;1065(2):321. Editor’s Notes: Abstract and Contact Information not provided.]

Gaulier J-M, Fonteau F, Jouanel E, Lachatre G. Rape drugs: Pharmacologicaland analytical aspects. Annales de Biologie Clinique 2004;62(5):529. [Editor’sNotes: A review. This article is writtten in French. Contact: Service depharmacologie et toxicologie, CHRU Dupuytren, Limoges, Fr.]

Grzybowski S. The black market in prescription drugs. Lancet Supplement -Medicine, Crime, and Punishment 2004;364:28. [Editor’s Notes: A brief overview.Contact: Dept. Of Family Practice, University of British Colombia, F-417, BCWomen’s Health Centre, 4500 Clark Street, Vancouver, BC, V6H 3N1, Canada.]

Johnson EL, Zhang D, Emche SD. Inter- and intra-specific variation among fiveErythroxylum taxa assessed by AFLP. Annals of Botany 2005;95:601.[Editor’s Notes: Presents the title study. Contact: USDA ARS PSI ACSL, 10300Baltimore Avenue, BARC-W, Beltsville, MD 20705.]

Lachenmeier DW. Hemp food products - a problem? Deutsche Lebensmittel-Rundschau 2004;100(12):481. [Editor’s Notes: An overview and review. Thisarticle is written in German. Contact: Chemisches undVeterinaeruntersuchungsamt (CVUA) Karlsruhe, Karlsruhe D-76187, Germany.]

Lyubavina IA, Zinchenko AALapenkov MI, Nikolaeva TL. An express morphineassay in aqueous samples by immunochromatography using monoclonalantibodies labeled with colloidal gold. Russian Journal of BioorganicChemistry 2005;31(1):99. [Editor’s Notes: Presents the title analysis. The


detection limit was 10 ng/mL, and the analysis time was 5 minutes. Contact:Russian Acad Sci, Shemyakin Ovchinnikov Inst Bioorgan Chem, UI MiklukhoMaklaya 16-10, Moscow 117997, Russia.]

Marris E. Police urge speedy action to clean up home drug laboratories. Nature2005;434(7030):129. [Editor’s Notes: Abstract and Contact Information not provided.]

Morris-Kukowski CL. gamma-Hydroxybutyrate: Bridging the clinical - analyticalgap. Toxicological Review 2004;23(1):33. [Editor’s Notes: Abstract and ContactInformation not provided.]

Ross SA, ElSohly MA, Sultana GNN, Mehmedic Z, Houssain CF, Chandra S.Flavonoid glycosides and cannabinoids from the pollen of Cannabis sativaL. Phytochemical Analysis 2005;16:45. [Editor’s Notes: Presents the title study;includes isolation procedures and chromatographic and spectral data. Contact:National Center for Natural Products Research, University of Mississippi,University, MI 38677.]

Semeikin NP, Sharshin YA, Gartsev NA, Belyi YI, Maksimov EM, Perederii AN,Reznev AA. NQR detector of explosives, narcotics, and metals hiddenunder people’s clothing. (Patent) Chemical Abstracts 2005:168594.

drug dog searches and asset seizures and forfeitures

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