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I've always had a problem with using K9s to establish PC. A K9 can't testify, nor swear out an affidavit for a search warrant. There is no objective way of verifying that the K9 signaled a hit; we have only the handler's word that the dog detected something. When a search subsequent to K9 detection turns up nothing, it's easily excused, but the unwarranted search still happened.

Using a K9 is a search, and should always be treated as such. I know the courts have ruled differently, but the courts have been wrong about lots of other things, too.