Quick v. United States

How later courts describe this case

• holding that the preponderance of the evidence standard should be used to make a Rule 801(d)(2)(E) determination in civil as well as criminal cases
• use of trained dog to sniff for contraband in area where officer and dog are not trespassing does not constitute an unreasonable search contrary to fourth amendment
• mere act of placing oil in storage tank does not give rise to liability
• mere act of placing oil in storage tank does not preclude recovery