Holmes’ words are very often used in attempts to quash politically incorrect speech. The key word in his statement, the one that the facists like to omit, is “falsely”. It IS protected speech, for one to shout “FIRE!” in a crowded theater, so long as it is actually ablaze. The lie that this movie trailer, IN ANY WAY “led to the attacks” is a damned outrage. These Camel-humpers can blame their bad behavior on anything that anyone says if this is allowed to stand.
That's exactly the end-result of the "Fire!" argument; anything can be barred so long as it is detrimental, in some way, to "public safety."
I hate that USSC decision, it is horrible; it is to the bill of rights what Wicard v. Filburn is to state sovereignty.