From today's Massachusetts high court opinion in Barron v. Kolenda, written by Justice Scott Kafker (and dealing with a claim brought under the state constitution's free expression provisions, rather than under the First Amendment):
[W]e conclude that the public comment policy of the town of Southborough (town) violates rights protected by art. 19 [freedom of assembly] and, to the extent it is argued, art. 16 [freedom of speech]. Under both arts. 19 and 16, such civility restraints on the content of speech at a public comment session in a public meeting are forbidden. Although civility, of course, is to be encouraged, it cannot be required regarding the content of what may be said in a public comment session of a governmental meeting without violating both provisions of the Massachusetts Declaration of Rights, which provide for a robust protection of public criticism of governmental action and officials.
What can be required is that the public comment session be conducted in an "orderly and peaceable" manner, including designating when public comment shall be allowed in the governmental meeting, the time limits for each person speaking, and rules preventing speakers from disrupting others, and removing those speakers if they do. We have concluded that such time, place, and manner restrictions do not violate either the right to assembly under art. 19 or the right to free speech under art. 16….
The policy provided, among other things, "All remarks and dialogue in public meetings must be respectful and courteous, free of rude, personal or slanderous remarks"; the event that triggered the lawsuit was this:
