This is interesting. Right of free speech is protected only versus the government. Private infringement of free speech is not protected. Heckling is a unique situation, though.
Audiences have a right to heckle... The leading judicial decision here is In re Kay of the Supreme Court of California... The Court granted the right to heckle and stated that this is a legitimate part of the “cacophony of democracy”. Even though heckling and booing and shouting and other types of disruption may be uncivilized, impolite and often stupid, it’s free speech and it should be protected. More...
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