from the research i've been doing. i've seen multiple cases where an "alert" of a qualified k9 is sufficient to provide probable cause to search a vehicle and luggage which are covered under the vehicle exception for a search warrant. but if a package is sealed, locked or wrapped to conceal the identity of what is being store within it requires a warrant. if a dog alerts on a suitcase being carried in an airport its subject to search. yet that same suit case being carried in a car would not be allowed to be searched because its not covered under the exception. so would a bag or container withing a suitcase also not fall under the same rules as the suitcase withing the car? the supreme court seems to be all over the place on this issue.