The definition of the word 'brandishing' usually includes qualifiers such as “in a rude, angry or threatening manner”, or something similar. However, in some cases in some places, just a simple momentary exposure of a weapon, not even necessarily a firearm, can be legally considered 'brandishing'.
That in itself is a very good reason for us all to work towards "Constitutional Carry" in every state across the country. That would eliminate all the indecision and confusion in our various gun laws. At some point we should all hope for a SCOTUS ruling on the 2nd that it means exactly what it says ..... nothing more-nothing less!
Just a little something to ponder y'all !!!