I also can't make sense of the article. The 1A clearly doesn't protect you from prosecution if you deliberately cause a disturbance by shouting "fire" in a crow

I also can't make sense of the article. The 1A clearly doesn't protect you from prosecution if you deliberately cause a disturbance by shouting "fire" in a crowded theatre. It's an uncontroversial example illustrating that the 1A has limits. The fact that this uncontroversial example was used in support of some controversial arguments ~100 years ago is neither here nor there.