Can a validly conducted dog sniff supply probable cause for a search warrant?

"A validly conducted dog sniff can supply the probable cause necessary for issuing a search warrant only if sufficient reliability is established by the application for the warrant." United States v. Spetz, 721 F.2d 1457, 1464 (9th Cir.1983). The Spetz court held that such reliability had been established. Id. The affidavit on which the Spetz search warrant had been secured stated that the dog had correctly alerted on 60 out of 66 occasions. Id. at 1464 n. 15. It also referred to the fact that another dog corroborated the "hit." Id. The Spetz affidavit did not state that the dog had been trained or certified to do narcotics detection work.