Depending on which survey you read, there are anywhere between 100,000 and 3.6 million defensive gun uses per year in the United States. One thing that almost everyone who studies such things agrees on is that, in a large number of the defensive gun uses that take place each year, no shot is ever fired. So, what separates displaying a firearm lawfully—or even justifiably pointing a firearm at another person—from a criminal charge of “brandishing,” or the unlawful display of a firearm?