Occasionally there are horses that are only marginally curly haired, and they can be difficult to determine whether they are actually a Curly Horse or not. Their coat is not very curly in the winter, and smooth in the summer. They are typically determined to be curlies when they have curly hair inside their ears. These horses are referred to as minimally expressed Curly Horses. Many folks make the mistake of calling bunny-haired Smooth Coat Curlies minimally expressed. Minimally expressed curlies are fairly rare.
With these horses, it is difficult for a photograph to show convincing identifying characteristics of a Curly Horse. Their coat is not very curly, and they may show little curl or wave in their manes or tails. They will almost always, however, show curly hair inside their ears. There may be more minimally expressed horses out there than we realize, being overlooked. They are not readily or easily identified as a Curly Horse by those who are unfamiliar with Curly Horse traits. Sometimes they are first identified when they produce a typical curly coated foal when bred to a non curly straight haired horse breed. There are a lot of smooth coated Curly Horses produced that have a bunny haired coat, swirled hair in their ears, and some twist to their manes. For now, until a genetic test is available to prove otherwise, those are called Smooth Coat Curlies, unless they produce curly coated foals when bred to straight horses.