Yelling fire(falsely) in a theater wasn't an example of breach of contract that is prohibited by a private agreement, but an understanding that the government h

Yelling fire(falsely) in a theater wasn't an example of breach of contract that is prohibited by a private agreement, but an understanding that the government has the right to prohibit speech made with the specific intent to create criminal harm. It's also not, as far as I understand, not the current legal standard, as of 2010's Holder vs. Humanitarian Law Project.