The analogy itself is dicta: part of the decision’s explanation and commentary; not a statement of law or binding precedent. Therefore not something that can be overturned in the subsequent case.

AFAIK the courts did not find this. After all, they were not considering the case of someone who shouted ‘fire!’ in a crowded theatre. If someone actually did this and people died as a result (e.g. in a stampede), it seems highly unlikely that a free speech defense could be used.

> It is relevant if the courts later overturned the decision and it is now considered free speech.

Since "it" is the draft stuff, not shouting fire, it's only mildly sometimes relevant.