From the article that was posted here in the OP's post.
"The female hunter was waiting for birds to be planted and had a firearm leaning against her body. The butt stock was on the ground and the muzzle was pointing upward".
I see "up", not at her body parts.
The interaction with the dog may (more likely) have moved the firearms point of aim.
But you are right, firearms should ALWAYS be unloaded & ammo kept separate .
Might not get as much game but it will be safer.