What is the standard of review for a suppression ruling?

The standard of review for a suppression ruling "is well established. We defer to the trial court's factual findings, express or implied, where supported by substantial evidence. In determining whether, on the facts so found, the search or seizure was reasonable under the Fourth Amendment, we exercise our independent judgment." (People v. Glaser (1995) 11 Cal.4th 354, 362.) Defendant does not challenge the underlying facts of the trial court's ruling, so we review the legal issues independently.

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"[T]he Fourth Amendment to the United States Constitution permits the warrantless search of an automobile with probable cause." (People v. Strasburg (2007) 148 Cal.App.4th 1052, 1059.) Probable cause exists when "there is a fair probability that contraband or evidence of a crime will be found in a particular place." (Illinois v. Gates (1983) 462 U.S. 213, 238 [76 L.Ed.2d 527, 548].) "[P]robable cause requires only a probability or substantial chance of criminal activity, not an actual showing of such activity." (Id. at p. 243, fn. 13) "Under California case law, 'A dog alert can provide the probable cause needed for a search warrant.' " (People v. Stillwell (2011) 197 Cal.App.4th 996, 1006.)