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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.
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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.