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During World War I, Charles Schenk was arrested for protesting and handing out pamphlets against the U.S. involvement in the war. In Schenk v. U.S., the courts upheld his arrest and stated that his actions would be like someone yelling "fire" in a crowded theater. What doctrine did the court come up with that states that limiting First Amendment Rights is okay if the National Interest could be harmed?

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