The "shouting fire in a crowded theater" referred to the Italian Hall Disaster [1], where union busters did precisely that. [1] https://en.wikipedia.org/wiki/I

The "shouting fire in a crowded theater" referred to the Italian Hall Disaster [1], where union busters did precisely that. [1] https://en.wikipedia.org/wiki/Italian_Hall_disaster https://en.wikipedia.org/wiki/Italian_Hall_disaster