Just pulling from your own quote: > is whether the words are used in such circumstances and are of such a nature as to create a clear and present danger The "

Just pulling from your own quote: > is whether the words are used in such circumstances and are of such a nature as to create a clear and present danger The "clear and present danger" standard is no longer used. It's been overturned in favor of the "imminent lawless action" standard. Falsely shouting fire in a crowded theater does not fall under imminent lawless action.