Remember, this is the case which determined it was lawful to jail war dissenters who were handing out "flyers to draft-age men urging resistance to induction."
Please remember to use an example more in line with Brandenburg v. Ohio: "falsely shouting fire in a theater and causing a panic".
> Your own link says that if you yell fire in a crowded space and people die you can be held liable.
(This is an example of how hard it is to dot all the i's when talking about this phrase. It needs a "falsely" as the theater may actually be on fire.)