That seems the other way around. In that case, the context made it clear that what could be notionally defended as an expression of frustration was in fact a call to act.

In this case, out of context, "let's have trial by combat" seems worse than when placed in the context that marks it as clearly metaphorical - he had just explained what he meant by it.

It's absolutely heated rhetoric, and one example of many - on the part of Giuliani, Trump, and others - that together built a context that led to violence.

It is absolutely appropriate to blame them for that.

That doesn't make labeling it a call for "trial by combat" a good representation of what happened in that moment.