I read "in stuck traffic" as 'in a traffic jam on a multilane freeway/highway with no end in sight. in NY and other east coast coast states it is a common occurrence. I often wonder if half the people are so crazy that they somehow think that honking their horn will have some magical effect to get traffic moving. The other half I wonder if they are just having fun releasing tension and joining in on a communal cultural ritual. I have been on both sides of the phenomenon. Looking from side to side seeing my fellow commuters in laughing hysterically or in rage.
Now it's possible an ESL person could interpret someone on their phone at a traffic light just turned green which they hadn't noticed as "in stuck traffic" I suppose. There are people who seem to be in a competition as to who can honk their horn the quickest after the light turns green, which I find a bit rude. On the east coast, the typical delay is about a second or quicker, but having lived in L.A. for decades, the delay can extend to ten seconds, twenty, maybe even longer. It seems to be much more rude to honk your horn in traffic in CA, unless it's an emergency, such as an imminent collision.
Being from NY, myself, if I find myself behind someone distracted by their phone after the light turns green in L.A., I'll give them maybe three seconds and then a very quick beep and a friendly wave, which seems to be a happy medium which avoids road rage.
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