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That is very subjective. Civil suit aside, it can be argued that doing so is a public disturbance, which can be a citation or in some cases, a misdemeanor
. However, it all depends on the elements surrounding the situation. Stopping traffic or flow of people on the sidewalk and causing a ruckus while flipping someone off may be criminally actionable.
Quickly flipping someone off is likely not.
Of course, this can be argued another way, since doing so is a sign for a vulgar utterance, and this can be construed as a public disturbance in itself.
Therefore, it is a highly subjective situation.
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