Facts: Drug Dog and Handler are training. The Handler (cop) asks the manager of a local self-storage facility for permission to run the dog along the storage units. The storage units are outside but access is controlled by security. Manager gives consent for Dog and Handler to conduct a walk around. Dog alerts on Defendant's unit. Handler comes to the DA and gets a search warrant, returns and finds 14g of meth.

We are at suppression and the Defendant claims that the manager did not have "authority" to consent to the training event on the premises...

Any words of wisdom or caselaw you know on point?

I would look under the cases on the landlord's authority to consent to searches of common areas of multiple unit dwellings. For instance, a landlord can consent to a search of the shared hallways of a 4-plex apartment.

A dog sniff is not a search. See United States v. Place, 462 U.S. 696, 707 (1983); Crockett v. State, 803 S.W.2d 308, 310 n.5 (Tex.Crim.App .1991); Ortiz v. State, 930 S.W.2d 849, 856 (Tex.App.-Tyler 1996, no pet.); Strout v. State
688 S.W.2d 188 (Tex.App. Amarillo 1985, no pet.) (sniff of safety deposit box).

The Minnesota Supreme recently addressed your situation and noted: "All of the state and lower federal court decisions that have addressed that issue have concluded that a dog sniff outside a storage unit is not a search under the Fourth Amendment." State v. Carter, 697 N.W.2d 199, 208
(Minn. 2005). The Court ultimately held that a sniff of a storage shed was a search under their state constitution.

If your guy is arguing that he has an expection of privacy not just in his shed but in the commerical facility generally you might look at Johnson v. Com., 2004 WL 178629 at *4 (Ky.App. 2004) (not published) ("In this case, the trial court did not err by concluding that the area surrounding a rented storage unit at a commercial storage facility does not equate with sanctity of a home for purposes of Fourth Amendment analysis.") or People v. Bautista, 115 Cal.App.4th 229, 8 Cal.Rptr.3d 862 (Cal.App. 6 Dist.,2004) ("Defendants had a protectable privacy interest in the storage locker that they rented. However, they did not have a protectable privacy interest in the air space around the locker or the air that emanated from the locker. (People v. Mayberry (1982) 31 Cal.3d 335, 341, 182 Cal.Rptr. 617, 644 P.2d 810.) Agent Muenchow and Sergeant Harris were rightfully in the public space of a public storage facility on an investigation unrelated to defendants.").

If by authority to consent your guy means that the manager violated some instruction from his employer, that wouldn't seem to raise a constitutional issue.

D - Thanks for the 411!

Obviously the handler was not trespassing. Just like anyone can walk up to your front door, surely some dog can walk up to a storage facility door! I would be focusing on the affirmative links if I were the defendant, and quit complaining about the sniff.