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Personally I think you should be free to yell "FIRE" in a theater too. If that started a panic and someone came to harm due to it then you might be held partially responsible to that harm, but so should those people who mindlessly trample on others without assessing the situation.

But if nothing happened then there should be no reason to make your exclamation illegal.

Of course you could still be thrown out of the theater for disrupting the performance, providing further disincentive for doing something like that, but that's separate from the legality of your speech.



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