Yeah… Technically, any refuse that isn’t placed into a proper receptacle is littering.
You know what cheeses me off the most though? Those collosal inconsievably childish idiotic morons who open their car doors, and empty the asktray in a parking lot! Are you some uncultured animal?? Why the hell did you bother putting them there in the first place?
We live in a society here! Man, if I had my way, BAM! a $1000 fine, and community service in the form of two full trash bags full of butts from a public place. That’ll learn 'em.