For being stupid
To me it is common sense if you are going to pocket carry, that gat belongs in a "Pocket Holster". I've heard and read about a lot of accidents, and near accidents concerning pocket carry, but not one involved a gun that was in a holster.
My partner had a student fling a Kel-Tec across a jewelry store that was posted when his keys got entangled in the trigger guard.
A few months ago a fellow in a nearby city carried his pocket gun in a bar, and when he reached for his keys discharged the a .380 into his girlfriends leg, bet a pocket holster would have been cheaper than all the charges he faced.
I also know of a guy that got in a situation, and pulled his 38 out of his pocket by the barrel, and pointed the grips at his attacker, lucky the appearance of the gun caused the bad guy to run.