Question about liability for inciting violence

[Rocknrule]

In the past, makers of violent movies and videogames have been sued for allegedly inciting school shootings. None of these lawsuits ever succeeded, of course, because in addition to the whole personal responsibility thing, upholding such a case would represent a direct assault on the 1st Amendment.

Now by the same logic, would Limbaugh or Coulter get off the hook if they inspired an act of violence and were sued by the victim's families? I think the circumstances would be different, because while videogame makers don't actively encourage people to commit violent acts (in fact, actively they discourage it), RW hate radio does, so there is malicious intent.