I agree that the first amendment doesn't apply in this case, but the "fire in a crowded theater" analogy is only used by people who aren't aware of its origin.

I agree that the first amendment doesn't apply in this case, but the "fire in a crowded theater" analogy is only used by people who aren't aware of its origin. The phrase was coined by Justice Oliver Wendell Holmes in WWI, in a SCOTUS decision to imprison socialists for leafleting against the draft.[1] 1. https://en.wikipedia.org/wiki/Schenck_v._United_States https://en.wikipedia.org/wiki/Schenck_v._United_States