In 1919, Supreme Court Justice Oliver Wendell Holmes wrote, "The most stringent protection of free speech would not protect a man in falsely shouting fire in a theatre and causing a panic." This famous maxim has often been cited to underscore the fact that free speech is not a viable defense when such speech is used to perpetrate a fraud. What is this limitation of our freedom of speech often

called?

What will be an ideal response?

Breach of the Peace