In People v. Harrington (1970) 2 Cal.3d 991, the police went to an apartment looking for a runaway juvenile. (Id. at p. 994.) The defendant answered the door, and identified himself upon the officer's request. When the officer asked if he could go inside, the defendant made no verbal response but stepped aside and made a gesture by extending his left hand. The officer entered the apartment and found marijuana in plain sight. (Id. at p. 995.) The court held that the defendant's gesture indicated an invitation to the officer to enter the apartment. The court held that "a consent to enter may be expressed by actions as well as words." (Ibid.)