If a hard shell case isn't an option on a brand new guitar I definitely wouldn't buy that brand. How can I trust a maker to make good design and build decisions if they don't think a case is important for a $1000 guitar?
Only two of my guitars have come with cases. Yeah, they're by far the nicest ones, and the fitment in them in fantastic. But it wasn't a deal breaker. I almost never need to move all my guitars at once, and they live on a rack, so I've got enough sturdy cases to move a few guitars to a gig or something as needed.
Its pretty dang important on most anything I would be buy over a certain price point. Part of it is principal, at such a price why should I have to buy what should have come with it when there are so many other options that do. Another part is certain brands must have the factory case IMO; PRS, Gibson or anything logo'd or sig'd.
Behind that, as regularly gigging musician, everything's gotta be in a hard case and preferably something stackable (f-ing Gibson's).