[Carl in Tampa]

Decades ago, the "securely encased" provision required that it must take "two actions" to put the pistol into use.

For example, the test was met if you had to 1. Open the glove compartment to access the pistol, and 2. Unsnap the holster in which it was contained to deploy it.

Holsters with no retention system would not be "securely encased."