When Did the 'fire in a Crowded Theater' Limit on Free Speech Appear?

On Factually, Adam Conover says the First Amendment's freedom of speech did not work, for much of American history, the way schools teach it now. The limit people remember, a clear and present danger such as shouting fire in a crowded theater, is a standard that protects political advocacy and was not enunciated until 1919, so that level of protection is about a century old. He sets the point up before introducing UCLA law professor Adam Winkler, author of Gunfight: The Battle Over the Right to Bear Arms in America and We the Corporations: How American Businesses Won Their Civil Rights.