There is no such thing as a “fire in a theater exception” to free speech. That case is often cited by the media, but it has been LONG overruled.
I don’t have the time to educate you at the moment, so here is some
Reading material:
https://scholarship.law.wm.edu/cgi/viewcontent.cgi?article=1748&context=wmborj
https://www.thefire.org/a-reminder-about-shouting-fire-in-a-crowded-theater/
Actually if you read the material it yes there, more accurately described as the “clear and present danger” standard.