Bit of a non-sequitor here but the classic example of yelling 'Fire' in a theater has me thinking about public safety. Obviously there have been many crowd-crush related injuries and fatalities throughout history. But we've also come a long way since the 1800's or 1900's with fire drills, emergency exits, etc.

It almost seems like any hazard or danger from a false alarm (intentional or otherwise) should be the liability of the owners or operators of a property for unsafe infrastructure or improper safety briefing.

Anyway, I don't expect that to appear as a major legal issue, given this is primarily used as a rhetorical example.