How big of a problem are “wolves in theaters” anyway?

In these here 57 United States, is the problem of people shouting “wolf” in crowded theaters so bad that the Constitution doesn’t cover it?

See, this is why whenever I go to the theater I make sure to bring a fully loaded .50 caliber Browning machine gun. The wolves, you see.  I can’t say anything about them, what with the freedom of speech now being curtailed.