Maybe their.. issue.. is more related to yelling ‘fire’ in a theatre.
https://en.m.wikipedia.org/wiki/Shouting_fire_in_a_crowded_t...
https://en.m.wikipedia.org/wiki/Shouting_fire_in_a_crowded_t...
The utterance of "fire!" in and of itself is not generally thought to be illegal within the United States> Ultimately, whether it is legal in the United States to falsely shout "fire" in a theater depends on the circumstances in which it is done and the consequences of doing it.
Edit: I am not agreeing with the parent that there is value in the comparison, only that the premise of the example is valid - i.e. that speech can have consequences dire enough to make it worth controlling that speech in certain contexts.