I think you’re misunderstanding the metaphor. Holmes was comparing “falsely shouting fire in a crowded theater” not to an example of false speech, but an examp

I think you’re misunderstanding the metaphor. Holmes was comparing “falsely shouting fire in a crowded theater” not to an example of false speech, but an example of inflammatory speech. Schenck wasn’t making false statements, he was encouraging resistance to the draft during wartime.