[Brandenberg](https://en.wikipedia.org/wiki/Brandenburg_v._Ohio) is the case you want to look at. The court held that, to be unprotected “incitement,” speech must meet three requirements. The speaker must intend to cause violence. The violence must be the likely result of the speech. And the violence must be imminent. So, if equivalent circumstances are established, yes, the shouter might well be in trouble.
Before you quote the "fire in a theater" precedent again, please go and look up [Schenck](https://en.wikipedia.org/wiki/Schenck_v._United_States) as well, since that's the origin of the quote, and because it's apparent that there is very little distance between "speech that will cause immediate harm to people isn't protected" and "speech criticizing wars isn't protected when we're at war" when you're a SCOTUS chief justice.
Before you quote the "fire in a theater" precedent again, please go and look up [Schenck](https://en.wikipedia.org/wiki/Schenck_v._United_States) as well, since that's the origin of the quote, and because it's apparent that there is very little distance between "speech that will cause immediate harm to people isn't protected" and "speech criticizing wars isn't protected when we're at war" when you're a SCOTUS chief justice.