Many people continue to labor under the old Feudalist canard that shouting "Fire!" in a crowded theater is not protected by the First Amendment. SCOTUS already struck that down 40 years ago. "The Atlantic" does a great job of detailing that here: https://www.theatlantic.com/national/archive/2012/11/its-time-to-stop-using-the-fire-in-a-crowded-theater-quote/264449/

The argument is that if I shout Fire!, and you bash an old woman's head in trying to get past her, then you are responsible for how you behaved and I am not. Regardless of whether or not there was a fire, or how dangerous that fire might be to everyone inside the theater, YOUR ARE RESPONSIBLE FOR HOW YOU BEHAVE, not me. If I had pointed to you and said, "Bash that old woman's brains in," and you did so, then both of us would go to jail.