A 54-year-old man called police names and made threats after they were called to a row in Colne, a court has heard.
Burnley magistrates were told how Chris Costello was arrested after officers came across him on Exchange Street, where two men were having a dispute. He then turned his aggression on the police.
Mrs Alex Mann, prosecuting, said: "I think at that time he was already restrained and cuffed."
Costello, who has a long record including for public order offences, has served several stretches behind bars - and he did not appear in court as he is again in jail.
The defendant, of Essex Street in Colne, admitted - through his solicitor - using threatening, abusive, or insulting words or behaviour on April 9th. He was fined £40, with a £30 victim surcharge.