FYI, the &quot;fire in a crowded theater&quot; phrase comes from Justice Oliver Wendell Holmes, Jr. in <i>Schenck v. United States</i>[1]. Writing for the majority (actually it was a unanimous decision), Holmes wrote:<p><i>The most stringent protection of free speech would not protect a man in falsely shouting fire in a theatre and causing a panic.</i><p>Many people nod their heads at this example, but they forget that Holmes was using it to justify the imprisonment of a man for leafletting against the draft. Those who earnestly reference &quot;fire in a crowded theater&quot; would likely stop if they knew its history. If anything, it argues against their point.<p>1. <a href="https:&#x2F;&#x2F;en.wikipedia.org&#x2F;wiki&#x2F;Schenck_v._United_States" rel="nofollow">https:&#x2F;&#x2F;en.wikipedia.org&#x2F;wiki&#x2F;Schenck_v._United_States</a>