Putting a chilling effect on protesters playing in the middle of the road

NY Times:

Citing Public Safety, States Seek Tougher Laws on Protesting

Republican legislators in at least 16 states have filed bills to make protests more orderly or to toughen penalties. Free-speech advocates say they will have a chilling effect.
There should be a chilling effect on demonstrating in the middle of a highway.  It is a danger to the protestors and to the public.  I do no think the 1st amendment protects someone lying down in the middle of the road.  There are already cases that say one cannot shout fire in the middle of a crowded theater.  You might say there is a chilling effect on shouting fire.  But that does not mean you get to do it.

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