Doe

MEMORANDUM *

In this forfeiture proceeding under Arizona Revised Statutes, section 13-4301 et seq., the State of Arizona appeals the district court’s summary judgment ruling that Phoenix police officers did not have probable cause to seize $80,045.00 in United States currency from claimant Mohamadou Sumareh (Sumareh). We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we affirm.

The State argues that it established probable cause when it presented evidence that a trained narcotics dog alerted to the smell of drugs on the currency that Sumareh was transporting. To evaluate whether probable cause existed, we must determine “ ‘whether the information relied upon by the government is adequate and sufficiently reliable to warrant the belief by a reasonable person that the [money] was’ connected to drugs.” United States v. U.S. Currency, $30,060.00, 39 F.3d 1039, 1041 (9th Cir.1994) (quoting United States v. One 56-Foot Yacht Named Tahuna, 702 F.2d 1276, 1282 (9th Cir.1983)) (alteration in original); see also United States v. $215,300 U.S. Currency, 882 F.2d 417, 419 (9th Cir.1989) (“ ‘To pass the point of mere suspicion and to reach probable cause, it is necessary to demonstrate…