Indeed most laws define "brandishing" a gun in terms of displaying a gun in a threatening or intimidating manner, or for the purpose of threatening or intimidating, or something to that effect.
Here in Michigan, an acquaintance of mine was legally carrying while driving down the road in his vehicle. His handgun was digging into his side, so while stopped at a light he removed the handgun(still in the holster) and set it on his passenger seat. Apparently a woman in a car next to him saw the gun and called the police with his license plate number. He was arrested only a few miles down the road and charged with "Brandishing in Public". Case was dismissed but he lost his CCW.