In Gallik v. Superior Court (1971) 5 Cal.3d 855, the officer stopped the defendant to tell him that his car was illegally parked. (Id. at p. 858.) While the officer was approaching the vehicle, he saw defendant briefly bend down to the right. (Ibid.) The officer asked for the defendant's license, pat searched him, and questioned him about "what he placed underneath the front seat." (Ibid.) After the defendant denied placing anything under the seat, the officer searched the car and seized marijuana. (Ibid.) The California Supreme Court held that the search was unlawful, because the suspicious circumstances of the defendant's furtive movement were not "sufficient to invest defendant's movement with guilty significance." (Id. at p. 860.) However, the court concluded that the officer reasonably questioned the defendant regarding his movement. (Id. at p. 861.)