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Hard to prove if it was secured without some sort of surveillance on the safe. But easy to prove if they have no records of ever owning a safe.
The "safe storage" laws are usually pretty worthless just on how they define "safe" on top of the actual problem with enforcement. They're not meaningful in any practical way, as anyone responsible enough that they should be allowed to own a gun already locks their shit down.
People who only lock their firearms away because they're required to are the reason shit like Nanovaults are so popular. They're a good-sounding concept, but in reality are held together with flimsy plastic internals. You can literally pry them open with a knife or housekey, or even just slam them onto the ground to pop them open.
tl;dr: Given the lax legal definition of a safe, using one doesn't necessarily add any meaningful security.
As an aside, I have safes for valuables and documents I'd like to survive a housefire...but I don't have any record of owning them. Were they stolen, I don't think it'd be easy to prove I didn't have them.
Sometimes that is enough. For example think of how poor the locks are on most front doors, how flimsy the frame is. There are many ways to defeat the pathetic security on most people’s houses yet they do actually discourage some break-ins. Many crimes of impulse can be prevented just by making it inconvenient enough for the impulse to pass or the perpetrator to find an easier target.
I’m not saying that is the case here, but I’d like to know if it is.
It's not. The reason I called out the specific Nanovault in another comment was that a friend had locked his (the gun bumped into the internal button to change the combination and it had gotten changed and was unknown, another ridiculous design flaw). Rather than mess around with cracking the new combination, I shoved the blade of my pocket knife into it, twisted it, and it popped open. Literally the same amount of effort/force and sticking a key into a keyhole and turning it, but without needing the actual key.
After realizing how secure it wasn't, he decided to test the other one he had before replacing them. Picked it up and dropped it from about waist height onto the garage floor (empty, no gun in it). It popped open, sending little plastic bits from the locking mechanism everywhere.
Yet, these are generally considered to meet the California legal standard of "a locked container or in a location that a reasonable person would believe to be secure."