"Yelling fire in a theater" was the reasoning used to shut down anti-war protesters 100 years ago and, IIRC, charge them with sedition. It's not a good example.
If you are alluding the Holmes’ judgement, he spoke not simply about free speech, but about actions in service to a market place of ideas.
His argument was in defense of the process to uncover truth.
Given that Fox has clearly said they cannot be taken seriously, and that they were from inception created to muddy the waters and wage war for political gain, they are an enemy to the process that was envisioned back in that era.
If someone is demonstrably selling false goods, and multiple sources have evidenced this, as has a court of law, should that all be dismissed because every single individual in America has not taken the time to look at the evidence?
At some point you abdicate roles and responsibilities to others, so that they can do the job of ensuring that a fair debate takes place.
