I'm tempted to say yes, but when i think about figure modeling, modeling in general and what most people think of as "art" I have to lean towards no. I think model making in general is art, but not neccessarily in the traditional sense. I'm not sure I'm prepaired to elevate one genre over the rest, though I will aknowledge that figure modelers are often a jock-of-all-trades within the modeling world.
But I think it's not so much that any one type of modeling is more art than another as it is that one can rise to the level of artist in any style. Are you an artist? Is it what you model or
how you model that makes you an artist?
I happen to believe that anyone who perfects any kind of model making is certainly an artist within the craft. Laying and then polishing a perfect clear coat to a mirror finish on a car model is art. The only easy thing about it is burning through the clear coat and into the color coat with your polishing process. Super detailing a tank interior is art. So is taking chuncks of wood and wooden rod stock, different gauges of string and thread, wire and tiny nails, and carving, cutting and milling it all into a perfect replica of the USS Constitution, complete with rigging and partial interiors, visible through the windows of the captain's quarters. Industrial Design/ Prototype modeling is an art.
However, I have noticed that most figure modelers are at least as skilled in one or two other types of modeling areas, while many other model makers typically aren't as good at figure modeling. I don't know why that is, but I do know that most of us came into model making through either armor, aircraft or cars, graduated to dioramas and came into figure modeling out of neccessity. For us, the figure painting/modifying/sculpting just took on a life of it's own.
I try to avoid the word elite, or other such euphemisms because there are people who can do things with a car model that I could never do in my wildest dreams and I am ever humbled by their work, as they are with mine. They are no less worthy of elite status than I.
Now, lets talk about "art".
I use many techniques and materials that fine artists use. My fine artist friends aknowledge my skills and are always amazed with my work, but I would never presume to count myself among them as a "fine artist", nor my work as 'art' in the same sense of the word as it relates to their work. I have always felt uncomfortable when talking to them and referencing myself as an "aritst". They're usually generous enough to accord me the title, but I am always in awe of their skills and would not, could not presume to stand beside them as a peer of equal merit.
Most of them went to school for several years to learn to sculpt and/or paint and have spent their entire adult lives perfecting their craft. While I've spent as much time with my hobby, and while I draw from much of the same skill sets and techniques that fine artists poses and use, I'm still, in that sense, just a model maker. Their work may someday be seen in a museum as part of an exhibit. Mine might too, but only as an annonymous diorama, built under contract for part of the Tutankhamen exhibit when it comes to town. While I consider figure modeling to be a 3 dimentional painting, it's just not quite in the same league as Monet, Homer or Picasso.