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Isn't this a "fire in a theater" event pretty much outside the 1st amendment protections.

Good question. What allegations, true or false, will incide some observers to violence, or otherwise create a foreseeable risk of injury (like a "Fire!" report does).

That a Koran was desecrated
That a Bible was desecrated
That a flag was desecrated
That police officers were acquitted in a trial alledging civil right violations
That prisoners were forced to wear panties on their heads

At least two of the above are adequate justification for violence or foreseeably puts people at risk of injury? And anybody who falsely utters one of those things ought to be punished?

"Fire in a theatre," I doubt it. Sloppy, mean-spirited reporting, to be sure.