Charley shakes after being bathed or brushed, if he's cold or if we've been outside for a long time and its cold and I've asked him if he needs to do more business and doesn't need to go.
He will tolerate being brushed or bathed but doesn't really like it so the trainer might be on to something?! But he's never shaken after obedience classes nor after a training session in the back yard so I'm not sure because once he's done a the command a few times he really isn't interested in doing in more times...
All that to say, I dunno!