Yes. Phone movement in a cup holder, on a seat or in a bag could register as a Distraction event. Best practice is to have a cradle or phone mount to keep your phone secure and on charge.
Note: Incoming calls, emails, or texts/notifications while driving will not count as a phone manipulation if you do not respond to them or swipe away notifications.
*Continued optimization is done regularly to ensure scenarios like normal phone vibrations or most horizontal slides are not recorded. As mobile handsets/applications evolve, the capture and assessment of sensor data will continue to improve.