In Williams v. State, 726 S.W.2d 99 (Tex. Crim. App. 1986), the officer approached a pickup truck parked on the wrong side of the street where the officer suspected a drug transaction was occurring. Id. at 100. The officer saw a man in the pickup truck, the defendant, make a downward motion. The officer saw a bag on the floor of the pickup, reached into the pickup, looked in the bag, and found a gun in the bag. The officer arrested the defendant for unlawfully carrying a weapon. Id. When asked why he reached into the pickup, the officer answered "narcotics and for my safety." Id. The court of criminal appeals held the search was a valid search incident to arrest because prior to the search, the officer had probable cause to arrest the defendant for the offense of illegal parking. Id. at 101. The court stated the fact that the officer "was investigating what he took to be a narcotics transaction is of no moment in this case." Id.In sum, in Williams v. State, an officer approached a truck parked on the wrong side of a street, where the officer suspected that a drug transaction was occurring. Id. at 99. The officer saw the defendant make a downward motion inside the truck, then saw a bag on the floor of the truck, reached inside and looked in the bag, and found a gun in the bag. Id. at 99--100. And the officer arrested the defendant. Id. at 99. At the hearing on the defendant's motion to suppress, the officer testified that he had reached into the truck to search for "two reasons. Narcotics and for his safety." Id. at 100. The Texas Court of Criminal Appeals upheld the search as a valid search incident to arrest because prior to the search, the officer had probable cause to arrest the defendant for the offense of illegal parking. Id. at 100--01.