That's certainly true. But also (from a investigation point of view) more suspicious than a filesystem covering the whole harddisk, but only filled to 20%. That will always be a problem, as long as the "visible" filesystem just maps block 1..N directly onto encrypted blocks 1+k..N+k (with k being a constant offset), as it's currently the case e.g. in linux LUKS (I assume CRYPTO discipline in BSD is similar).

The proper solution most likely would be to integrate a kind of block-mapping into the encryption software which allocates randomly distributed blocks from the encrypted harddisks whenever a filesystem begins to write to the blocks of an volume. This randomization algortithm then will be aware of all currently active "hidden partitions", but due to the randomness, a pattern to draw conclusions about the existence of other partitions would not emerge.