AFAIK the courts did not find this. After all, they were not considering the case of someone who shouted ‘fire!’ in a crowded theatre. If someone actually did t

AFAIK the courts did not find this. After all, they were not considering the case of someone who shouted ‘fire!’ in a crowded theatre. If someone actually did this and people died as a result (e.g. in a stampede), it seems highly unlikely that a free speech defense could be used.