Shouting fire in a crowded theater

One of the great thing about this country is the first amendment. But the courts have limited the first amendment particularly [Brandenburg v. Ohio in 1969].

Certain news outlets realized that they could boost rating over the Ebola crises by sensationalizing the problem. They are making good money on using fear to boost ratings. Fear is the currency of tyrants and scoundrels. People in Africa have sold worthless medical kits and profited by it. But how different is it to profit by using unscientific panic to boost ratings.

Ebola is a huge issue but creating an environment of fear may have the effect of causing people who need help not to seek it. This has happened in the effected region of Africa already. Even worse those providing medical help to the sick will be discriminated against and reducing those resources. Making it more likely to cause problems in handling this problem. At which point does it become similar to "Shouting fire in a crowded theater" or likely to incite imminent lawless action.