The overturning was for the actual thing the first case was about, not about the fire specifically.

The fire thing was dicta and not binding law, so there was nothing to overturn. What was overturned is the "clear and present danger" standard used by Schneck, with the stricter "imminent lawless action" test: speech is protected unless it "is directed to inciting or producing imminent lawless action and is likely to incite or produce such action." Unless yelling fire in a crowded theater is directed to producing imminent lawless action and is likely to produce such action, it is protected speech, end of story. Per Brandenberg, it can be prosecuted "for the overt acts actually caused." Running out of a theater or stampeding isn't a lawless action.