The article says that certification establishes a presumption of reliability. That means that certification can shift the burden of proof to the defendant. In

The article says that certification establishes a presumption of reliability. That means that certification can shift the burden of proof to the defendant. In that case, Bentley would have to prove to the jury that the dog is unreliable. It's correct. It seems Bentley's trial counsel erred by not presenting evidence that the dog was unreliable, and hence did not meet Bentley's burden. [Edit: clarity]