I have seen the bogus LE arguments, "Duh, the side laying against the seat could not be seen and was therefore concealed." Or some poor stupid gunowner scared into pleading guilty to a concealed weapon charge because the gun was in a case locked in the trunk.
Many states specifically define "concealed weapon" specifically as being concealed upon your person, that is, on your body, covered with clothing such that it is not visible, and further state that the pistol being in a holster, even if a flap type, on the belt, is not concealed... even if you cannot see the weapon, but only the holster. Read YOUR state law here. And never plead guilty to these bullshit charges.
Defining a weapon as concealed by being in a case makes you a lawbreaker. Having a weapon in plain view exposes you to charges of "brandishing a weapon" if held in your hand, and not carried in a holster or case. So, if both of these are true, then it is impossible for you to Keep and Bear Arms, as the Constitution says. It would be impossible to take a gun hunting, to the range, or simply carry it to your friends house. The laws conflict. This type of crap is makings for a good lawsuit at the very worst.
Lawyers here to comment?