I forget who originally posted this, but the below might work since it allows you to define how large an area a titlebar would be. Basically, you can't shove the window up further than the lower extreme of a titlebar since you have nothing to grab onto.

Code:
        static RECT titleRect  = { 0, 0, 300, 90  };    
                    
        case WM_LBUTTONDOWN: 
            {
            POINT pt = { LOWORD(lParam), HIWORD(lParam) };
            if ( PtInRect(&titleRect, pt) )
            SendMessage(hwnd,WM_NCLBUTTONDOWN,HTCAPTION,lParam) ;
            return 0 ;
            }
Another option you could look into would be to set up the up/down arrow keys & move your window that way as well.