Cunningham v. State (2000)
In Cunningham v. State, 11 S.W.3d 436 (Tex.App.--Houston 14th Dist. 2000, no pet.), the appellant was pulled over for speeding and while running the background check on appellant's license, the officer noticed appellant making "'overt movements' by 'constantly reaching over to the floorboard of the passenger's seat.'" Cunningham, 11 S.W.3d at 438.
The Court held that the marijuana residue gave the officer probable cause to believe that the vehicle contained a lager quantity of marijuana. Id. at 440.