The judgment comes in when you're trying to determine if an advantage was gained, but the only reason a dribbler would have his forearm up to begin with would be in trying to keep the defense away from the ball (after all, it's not a "natural" way to be dribbling). No foul, of course, if contact is not made, but if there IS contact then we have to determine if it is sufficient to call a foul. If it's an "exaggerated" arm out, as young players often tend to do, then it doesn't require a great deal of contact to gain an advantage. 'Course, with younger players I'm first going to explain to them NOT to hold their arm up and out before I call a foul on them.
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