Meh, the 'yelling fire in a crowded theater' is, rightfully, not protected under free speech but "hate speech" (which has no legal definition in the US) has consistently been allowed by the Supreme Court. Doubt we'll reach a hate speech exemption anytime soon.
The the phrase "shouting fire in a crowded theater" has am interesting history.
It does not come from an an actual precedent, but dates back to a supreme court decision that prohibited political speech on opposition to the draft during WWI.
In my opinion, the unanimous decision on that case is a travesty and the use of the term to justify abrogating free speech indicates a lack of understanding of the history of the government abrogating free speech when it serves their interests rather than for the common good.
