I'd like to point out that "shouting fire in a crowded theater" is a rhetorical analogy that was invented to justify the suppression of legitimate political speech. (Namely to silence opposition to the draft.)
That's true, and was obviously an overreach in 1919. That it was dialed back in 1969 to limit banning speech likely to incite a riot is much more reasonable to my mind.
I do not think it is unreasonable to assume Trump stating he had won was actually an attempt to incite riots and looting. He seems to really enjoy chaos. Into the history books by hook or crook.
