Bent pushrod or if the car had not been run in a while, I believe a stuck valve could cause that problem. For example, the lifter and pushrod drop with cam rotation to allow valve to close. since the valve is stuck open the rod has the opportunity to drop out of the pocket in the rocker arm and then just ride around there in the engine. Same thing happened to me on my old slant. I checked the valve and made sure the lifter was correctly placed in its hole. I put the push rod back after I verified it was straight and rotated the engine slowly by hand to ensure the whole works was okay. Then back to normal operation like it never happened.