Big key word here, 'or'. Law just states it needs to be 'unloaded' which is pretty much always unless you're shooting lol. Back seat counts as not readily accessibleI agree a bow case and moisture can make a mess but here you can not transport a bow without it in a case and has to be zipped up. Unless MI law has changed I'd love to have it out of case to hang on back of seat to dry on way home.